Belgium Tax News
Comments on draft contents of 2008 update to Model Tax Convention published
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital
Preliminary ruling requested from ECJ regarding compatibility of Belgian tax treatment of foreign dividends with EC free movement of capital
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
Treaty between Belgium and Singapore ratified
Belgian ruling that 95% dividend deduction applies to dividends received from Thai companies benefiting from tax holiday via intermediary companies in third states
Treaty between Belgium and Luxembourg – Belgian ruling that income from real estate certificates classified as interest
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Notional interest deduction – Circular on anti-abuse measures published
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
Treaty between Belgium and Chile – details
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive
Treaty between Chile and Belgium signed
European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
Treaty between Qatar and Belgium ratified
Treaty between Belgium and France – Court of Appeal of Brussels decides compensation received per non-competition clause classified as employment income
Protocol to treaty between Brazil and Belgium – details
Treaty between Belgium and Qatar – details
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
Treaty between United States and Belgium enters into force
OECD released discussion draft on transactional profit methods
Treaty between Israel and Belgium: Israeli District Court decides domestic anti-avoidance rules may deny treaty benefits
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