Belgium Tax News
ECJ: Netherlands' non-exemption of dividends paid to certain EEA countries from withholding tax found incompatible with EEA Agreement
Protocol between Germany and Belgium initialed
In a press release of 15 May 2009, it was announced that the Belgian Council of Ministers decided to bring the Belgian participation exemption in line with the decision of the European Court of Justice (ECJ) in Cobelfret (C-138/07).
Protocol to treaty between Belgium and Netherlands signed
ECJ: Cobelfret extended to domestic situations and potentially to dividends received from third countries
ECJ finds Finnish dividend withholding tax regime incompatible with EC freedom of establishment
Belgian government decides to bring Belgian participation exemption in line with Cobelfret
Protocol to treaty between Belgium and France ratified
Treaty between Belgium and Tunisia ratified
Treaty between Belgium and Tunisia approved
European Commission refers Germany to ECJ over taxation of outbound dividends
Protocol to treaty between Belgium and France approved
Treaty between Belgium and Morocco ratified
ECJ: Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive
Treaty between Belgium and Oman – details
Circular on notional interest deduction published
Treaty between Singapore and Belgium enters into force
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies resident in other Member States justifiable restriction on EC freedom of establishment – details
ECJ: Advocate General finds Belgian withholding tax on interest paid to companies resident in other Member States compatible with EC freedom of establishment – details
Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages
Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment
OECD released 2008 Model Tax Convention
Treaty between Belgium and France: regular participation in commodity exchange held to be permanent establishment
Proposal to implement amendments to EC Merger Directive
Withholding tax on copyrights and similar rights introduced
Discussion draft on New Art. 7 of OECD Model – details
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax
OECD Council approves 2008 Model Tax Convention
Treaty between Italy and Belgium – Italian tax authority rules on tax qualification of payments under non-competition agreement
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