Belgium Tax News
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Belgian rules for set-off of losses with third-country PE's profits discriminatory
Treaty between United States and Belgium ratified
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
Amending protocol to treaty between Belgium and Brazil enters into force
Treaty between Chile and Belgium – negotiations
Treaty between Qatar and Belgium signed
Court rejects reclassification of service fees into dividends on basis of general anti-abuse provision
Treaty between United States and Belgium approved
Treaty between Belgium and Bahrain signed
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details
Preliminary ruling requested from ECJ regarding compatibility of Belgian participation exemption with Parent-Subsidiary Directive
Treaty between Czech Republic and Belgium – Taxation of industrial royalties to be amended (MFN)
Treaty between Brazil and Belgium – Brazilian Congress approves amendments to treaty
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system
Belgian court requests preliminary ruling from ECJ on limitation of waiver of withholding tax to interest allocated to resident companies
Draft Model Convention for tax treaty negotiations published
AG: Most-favoured nation treatment and Community preference do not require extension of the tax sparing credit under tax treaties with Brazil and Greece to third countries
Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Belgian abolition of fixed FTC incompatible with tax treaty between Belgium and US
US Senate hearings on new treaty and protocol between Belgium and US
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
Treaty between Belgium and Netherlands – Court of Appeal Ghent holds stock of goods does not constitute PE
Different tax treatment of full and partial repayment of subscribed capital not discriminatory
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