News

2025/12/04: Pillar2 - Enormous compliance costs for Belgian companies
Following the remarkable intervention by Alexia Bertrand (group leader of the Open Flemish Liberals and Democrats Open Vld) in the Finance Committee ...
2025/12/01: Publication of an impressive report by the Commission on DAC. Does the Commission suffer from a democratic deficit ? Impact of DAC2 on the capital gains tax in Belgium ?
The Commission has recently published its evaluation of the EU Directive on Administrative Cooperation in Taxation (DAC) (full report [1]). It is o ...
2025/11/10: Update transfer pricing : premiums paid to a Swiss captive reinsurance company (Ghent, 6 June 2025)
🔅 The Court of First Instance of Ghent recently ruled in favour of the taxpayer in an interesting transfer pricing dispute involving a Swiss captiv ...
2025/11/05: SICAV RDT - DBI Beveks : The new 5% capital gains tax misses its target (preparatory works)
While reading the preparatory works of the draft law of 3 July 2025, I came across one of my statements in April 2025 in De Tijd ( [1]) on the new 5% ...
2025/10/23: Case-law: Application of the general anti-abuse rule (art. 344,§1 ITC, GAAR) : denial of domestic foreign tax credit on royalties received by a Belgian SCS (Hybrid) (Trib. Liège, 21 octobre 2024)
On 21 October 2024, the Court of First Instance of Liège rendered a remarkable judgement in favour of the tax authorities, denying the application of ...
2025/08/19: Recent case-law (Johnson Controls case): (i) EU principle of prohibition of abuse - (ii) Transfer pricing (Court of First Instance of Leuven, 6 June 2025
The Belgian newspaper L'Echo has reported that a Belgian subsidiary of a US MNE (Johnson Controls) has been caught in the tax net. I had the pleasure ...
2025/07/07: New reporting obligation of certain share deals (SPA) under the preliminary draft bill with respect to the new capital gains tax Will it come through?
🔸 The partners of the new arizona coalition have reached an agreement on the new capital gains tax last Monday (30 June). 🔸 Based on the preli ...
2025/07/02: Capital gains on funds units : interaction between art. 19bis ITC (Reynders tax) and the new 10% capital gains tax
A political agreement has been reached last Monday with respect to the details of the new tax of 10% on capital gains with respect to financial assets ...
2025/05/28: Not so easy for Luxembourg SICAV to successfully rely on the Belgium-Luxembourg DTT...
I am happy to share my last article in L'Echo [1] co-authored with my colleague Arnaud Leroy.   For Luxembourg SICAV, successfully invoking ...
2025/05/22: Is the Cayman Tax applicable to master-feeder fund structures ?
This is one hot topic for Belgian tax practitioners dealing with fund structuring involving (on top) Belgian individuals (HNWI). 1. Definition of " ...
2025/05/19: Participation exemption regime : new condition of financial fixed asset. Why does the size of the holding company matter? Is dividend income considered as turnover? Opinion of the Council of State
I have provided some insights in L'Echo (article of Philippe Galloy [1]) into (i) the impact of the strenghtening of the Belgian participation exempti ...
2025/05/07: New Exit Tax : contrary to EU tax law?
I shared my insights in the financial newspaper De Tijd about the preliminary draft bill concerning the new capital gains on financial assets. The que ...

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