Author: Loyens & Loeff Publication date: 26/02/2019 On 26 February 2019, the Court of Justice of the European Union (CJEU) issued its judgments in six cases which deal with the interpretation of the Parent-Subsidiary Directive (PSD) and the Interest & Royalties Directive (IRD, together the Directives). The CJEU stated that
On 7 June 2017, the OECD BEPS project reached its next milestone with the signing of the multilateral instrument (“MLI”) by 68 jurisdictions during a signing session in Paris. The Netherlands, Belgium, Luxembourg and Switzerland signed the MLI. Being one of the most revolutionary aspects of the BEPS project, the
The United Arab Emirates become the 109th jurisdiction to join the most powerful multilateral treaty against offshore tax evasion and avoidance (TaxLive)
The Convention is the most powerful instrument for international tax cooperation. It provides for all forms of administrative assistance in tax matters: exchange of information on request, spontaneous exchange, automatic exchange, tax examinations abroad, simultaneous tax examinations and assistance in tax collection. It guarantees extensive safeguards for the protection of
On February 21, 2017 the EU Member States reached agreement on a Directive that will amend the Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164 of July 12, 2016, 'ATAD 1'). The new Directive (‘ATAD 2') amends Article 9 of ATAD 1, which covered certain hybrid mismatches between EU Member States.
The main changes to be expected in Belgium in the context of the implementation of the ATAD (Interest limitation – Exit taxation – GAAR – CFC – Hybrid mismatches).
Rather than pursuing companies such as Apple for what they did in the past, we should focus on shaping a fair tax system for the future.