News

2024/07/17: 'Belgium anticipates a new influx of French tax exiles'.
Le Monde has published an interesting article on the potential influx of "tax exiles' (exilés fiscaux) in Belgium, following the (relative) victory o ...
2024/07/02: Transfer of seat- Withholding tax - Parliamentary question
In a recent parliamentary question dated 18 December 2023, the deputy Marco Van Hees asked the minister of Finance what his stance is on the tax aspec ...
2023/09/19: 'INTEREST PAYMENTS BY A BELGIAN COMPANY TO A LOW-TAXED SWISS GROUP ENTITY : NO WITHHOLDING TAX EXEMPTION.'
The Court of first instance of Brussels ruled on 21 April 2023 that interest payments made by a Belgian company to a low-taxed Swiss company could not ...
2023/06/01: Minimum tax of 15% on MNE – Belgian IP Box
The draft legal texts transposing the 15% minimum tax into Belgian law are ready (implementation of the EU Directive 2022/2523 of 14 December 2022). ...
2023/05/26 : Outbound transfer of seat : taxable dividend?
For the first time, a Belgian court has ruled on the question whether an outbound transfer of seat of a Belgian company could trigger a dividend (with ...
2023/03/15: The substance of foreign holding companies : a paradigm shift
A lot of Belgian residents (HNWI, Belgian group of companies,...) use a Luxembourg holding (the so-called SOPARFI) as part of their tax planning. I ...
2023/03/09: The modification of the Belgian ruling procedure : quo vadis?
The draft legal texts of the Belgian tax reform contain a set of provisions aiming at amending the tax ruling procedure. Two key takeaways: - th ...
2023/01/01: Investment by a Luxembourg SOPARFI in tax exempt investment funds
In a decision dated 31 March 2022, the Luxembourg Administrative Court of Appeal denied the application of the Luxembourg participation exemption regi ...
2022/12/31: Luxembourg : requalification of an interest free loan into a deemed contribution
In the last issue of Agefi, I comment a recent judgment dated 23 September 2022 in which the Luxembourg administrative tribunal requalified an interes ...
2022/10/11: General anti abuse rule : must the taxpayer implement himself all the steps of an arrangement?
In a recent ruling, the application of the Belgian anti-abuse provision laid down in article 344(1) of the Belgian Income Tax Code (BITC) was rejected ...
2022/10/10: DAC 6 : recent developments in Belgium
In its second action plan against tax and social fraud, of 1 April 2022, the Belgian government announced that the Belgian tax authorities have been r ...
2022/08/13: How are stock spinoffs taxed at the level of the common shareholder / Belgian individual ?
How are stock spinoffs taxed at the level of the common shareholder / Belgian individual ? Is the distribution by a company (parent) A of the share ...

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