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Orbitax Tax News & Alerts

Belgium's Tax news & updates from Orbitax and partners

Belgium Tax News

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Final Report on Improving the Resolution of Tax Treaty Disputes

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Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement

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ECJ: hearing in case regarding Dutch withholding tax on outbound dividends

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Report on Attribution of Profits to PEs released

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EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

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EU Commission requests Italy to implement the Interest and Royalties Directive correctly

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EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

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Treaty between Germany and Belgium - Mutual agreement concerning treatment of severance payments

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New treaty between Belgium and US signed

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ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details

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ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment

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New treaty between Belgium and Singapore – details

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Budget for 2007 – details

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European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

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European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive

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European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid

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European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures

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European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends

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Draft Bill on tax plans for 2007 issued

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Belgian Minister of Finance clarified application of Belgium–Hong Kong tax treaty

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Protocol between Belgium and New Zealand – negotiations

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Ruling on profit attribution between Belgian headquarter and Mexican branch published

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Different treatment of interest derived by Luxembourg PE of Belgian enterprise, and by Luxembourg fixed base of Belgian professional, under Belgium-Luxembourg treaty not incompatible with equality principle of Belgian constitution

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Treaty between Belgium and Greece enters into force

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The first-time income tax treaty and protocol between Belgium and Taiwan, signed between the Taipei Representative Office in Belgium and the Belgian Trade Association in Taipei on 13 October 2004, entered into force on 14 December 2005. The treaty generally applies from 1 January 2006.

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Budget law 2006 approved

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Greece ratified the new Greece-Belgium income tax treaty, signed on 25 May 2004, by way of Law 3407/2005 and published in the Official Gazette of 25 October 2005, Volume A, No. 266. The new treaty will generally replace the Greece-Belgium income tax treaty of 24 May 1968.

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Decree to clarify application of notional interest published

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Mnster tax court refers to ECJ treaty-override provision in German Foreign Tax Law re low-taxed passive foreign PE income

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Exemption method to avoid double taxation of employment income determination of denominator in apportionment formula

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