Belgium Tax News

ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details

4 November 2007

Treaty between Brazil and Belgium – Brazilian Congress approves amendments to treaty

4 November 2007

Preliminary ruling requested from ECJ regarding compatibility of Belgian participation exemption with Parent-Subsidiary Directive

4 November 2007

ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system

4 November 2007

Treaty between Czech Republic and Belgium – Taxation of industrial royalties to be amended (MFN)

4 November 2007

Belgian court requests preliminary ruling from ECJ on limitation of waiver of withholding tax to interest allocated to resident companies

1 October 2007

Draft Model Convention for tax treaty negotiations published

1 October 2007

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

2 September 2007

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

2 September 2007

OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007

Different tax treatment of full and partial repayment of subscribed capital not discriminatory

29 July 2007

Belgian abolition of fixed FTC incompatible with tax treaty between Belgium and US

29 July 2007

US Senate hearings on new treaty and protocol between Belgium and US

29 July 2007

EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends

29 July 2007

ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details

29 July 2007

Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published

29 July 2007

ECJ: Finnish group contribution regime compatible with EC Law – details

29 July 2007

Treaty between Belgium and Netherlands – Court of Appeal Ghent holds stock of goods does not constitute PE

29 July 2007

EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends

29 July 2007

ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details

2 July 2007

ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details

2 July 2007

ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law

2 July 2007

ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details

2 July 2007

ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details

2 July 2007

Treaty between Belgium and Luxembourg – Luxembourg Administrative Court of Appeal decides denial of group tax treatment compatible with non-discrimination provision

2 July 2007

International tax conference on CCCTB held in Berlin

18 June 2007

Treaty between Belgium and US ratified

18 June 2007

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

18 June 2007

Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007

Bill on various direct tax and VAT measures adopted

18 June 2007