The OECD BEPS Action Plan and parallel developments impact each layer of a multinational structure, including the upper tier. Specifically, having insufficient relevant substance at upper tier level could cause your return on investment to decrease significantly (by up to 25% based on the current Belgian withholding tax rate). On top, we expect that the
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Most popular news
- New ‘60-day rule’ for pension funds: the practice note was published
- Investment deduction for assessment year 2020 published
- Shareholder Rights Directive II. Financial institutions, are you prepared?
- Important changes to the regime of specialised real estate investment funds (FIIS/GVBF)
- Belgian Ratification of the MLI: a Game Changer in the International Tax Field