News

2026/05/26: Case-law: Belgian DJ company with a PE in Dubaï (UAE) - no participation exemption (DRD) at the level of the Belgian holding company (Court of First Instance of Antwerp, 4 March 2026)
Importance of delivering accurate/correct tax advice in international tax planning : € 17mio damages recently awarded to a Dutch DJ (Amsterdam Court ...
2026/05/04: Case-law: When another passive holding company gets caught in the tax net! Denial of the participation exemption regime (Court of Appeal of Mons, 21 January 2026)
On 21 January 2026, the Court of Appeal of Mons denied the application of the DRD Regime on dividends (approx. 22mio €) distributed by a Belgian com ...
2026/01/22: Drawing against an International Master
I have just faced a Polish IM (Michal Luch, 2353 ELO FIDE) in a chess tournament in Spain and managed to draw (the IM title ranks just below the title ...
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 ...

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