Orbitax Tax News & Alerts
Belgium's Tax news & updates from Orbitax and partners
Belgium Tax News
Treaty between Czech Republic and Belgium – Taxation of industrial royalties to be amended (MFN)
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
Different tax treatment of full and partial repayment of subscribed capital not discriminatory
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
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
ECJ: Finnish group contribution regime compatible with EC Law – details
Treaty between Belgium and Netherlands – Court of Appeal Ghent holds stock of goods does not constitute PE
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Swedish legislation on dividend tax relief in relations with third countries is 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
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
Treaty between Belgium and Luxembourg – Luxembourg Administrative Court of Appeal decides denial of group tax treatment compatible with non-discrimination provision
International tax conference on CCCTB held in Berlin
Treaty between Belgium and US ratified
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
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Bill on various direct tax and VAT measures adopted
ECJ: Preliminary ruling requested on Belgian implementation of the Parent-Subsidiary Directive
Tax deduction for patent income to be introduced
Revised Commentary on Article 7 of OECD Model released
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
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