Belgium Tax News
ECJ: Finnish group contribution regime compatible with EC Law – details
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
Treaty between Belgium and Luxembourg – Luxembourg Administrative Court of Appeal decides denial of group tax treatment compatible with non-discrimination provision
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
International tax conference on CCCTB held in Berlin
Bill on various direct tax and VAT measures adopted
Dutch Supreme Court decides that Netherlands not obliged to grant credit for Brazilian and Italian withholding tax on interest derived by Belgian PE of Dutch company
Treaty between Belgium and US ratified
Revised Commentary on Article 7 of OECD Model released
ECJ: Preliminary ruling requested on Belgian implementation of the Parent-Subsidiary Directive
Tax deduction for patent income to be introduced
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Final Report on Improving the Resolution of Tax Treaty Disputes
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Treaty between Germany and Belgium - Mutual agreement concerning treatment of severance payments
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
Report on Attribution of Profits to PEs released
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
New treaty between Belgium and US signed
New treaty between Belgium and Singapore – details
Budget for 2007 – details
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
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