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Restructuring Recommended After CJEU Decision On Intra-EU Bilateral Investment Treaties
On March 6, 2018, the Court of Justice of the European Union ("CJEU") issued a judgment in the Achmea v. Slovakia case on whether the investor–state ...
European Union
26 Mar 2018
State Aid In Disguise?—EC Investigates UK Tax Regime
The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules.
13 Dec 2017
Protocol Amending The Mexico–Belgium Tax Treaty Published
On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion between Belgium and Mexico was published in Mexico's Official Journal...
12 Sep 2017
Modernizing The European VAT System For Cross-Border B2C E-Commerce
In a world where e-commerce is on the rise, it has long been recognized that the current European Union Value Added Tax ("VAT") rules and formalities are woefully outdated.
European Union
25 Jan 2017
New Flexible Real Estate Investment Vehicle In Belgium
The Brexit decision has raised questions as to whether London's role as the financial capital of Europe may be altered and therefore open the way for other European cities to reposition themselves as financial centers.
19 Dec 2016
EC Rules That Apple Received Illegal State Aid Under Irish Tax Rulings - Orders Recovery Of Up To €13 Billion
The Commission concluded that Apple must pay Ireland an amount equal to the alleged tax benefits, plus interest, amounting to some €13 billion.
European Union
2 Sep 2016
The Anti-Tax Avoidance Package
The European Commission's proposed "Anti-Tax Avoidance Package" comprises three core pillars: Ensuring Effective Taxation, Increasing Tax Transparency, and Securing a Level Playing Field. But the Package is subject to unanimous approval of all Member States, likely resulting in changes to its provisions and a delay in its implementation.
European Union
22 Feb 2016
EU Rules Starbucks, Fiat Received Tax Advantages From The Netherlands And Luxembourg Constituting Illegal State Aid, Must Pay Back Taxes
Today, October 21, 2015, the European Commission (the "Commission"), acting as the regulator of EU competition rules, announced that it had concluded that tax rulings obtained by a Dutch subsidiary of Starbucks and a Luxembourg subsidiary of Fiat conferred illegal State aid to those companies.
European Union
22 Oct 2015
Luxembourg Leaks: Potential Risks To Companies Whose Luxembourg Tax Rulings Have Been Released To The Public
This week, the so-called "International Consortium of Investigative Journalists" ("ICIJ"), on its website, leaked a total of 548 tax rulings that multinational companies obtained in Luxembourg in the period from 2002 to 2010.
10 Nov 2014
Recharged Costs And Expenses Of Stock Option Plans Not Tax Deductible For The Belgian Employer
On June 25, 2014, the Brussels Court of Appeal confirmed an earlier ruling (dating from 2010) from the Tribunal of First Instance.
13 Oct 2014
Belgium Modifies Its Notional Interest Deduction Regime To Comply With EU Law
Argenta Spaarbank NV challenged the validity of the exclusion of the net book value from the computation basis for the notional interest deduction.
9 May 2014
Public Disclosure Requirements For Private Companies: U.S. vs. Europe
The mandated disclosure regime for publicly traded companies is similar in the U.S. and Europe, and significant disclosure is required.
United States
29 Oct 2012
Treasury Issues Proposed Regulations On The Information Reporting And Withholding Tax Provisions Of FATCA
On February 8, 2012, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service (the "IRS") released proposed regulations (the "Proposed Regulations") implementing the Foreign Account Tax Compliance Act ("FATCA") provisions of the Hiring Incentives to Restore Employment Act enacted on March 18, 2010 ("HIRE").
United States
24 Apr 2012
Belgian Qualified Stock Option Plans Can Be Extended By Five Years - But Only By Electing Before July 31st
Belgian corporate taxpayers that have a Regulated Stock Option Plan ("RSOP") in place that complies with the Law of March 26, 1999, can extend the exercise term of those options by up to five years without triggering additional Belgian income tax for the beneficiaries, provided appropriate action is taken before July 31, 2009.
European Union
13 Jul 2009
International Tax Planning: Belgium is Taking Steps to Enhance its Attractiveness
Belgium has long been considered an interesting jurisdiction for various tax-planning and structuring purposes. Capital gains on shares are normally tax-exempt, dividends can be received nearly tax-free, interest paid on loans taken out to acquire shares is still tax-deductible, and Belgium has had a very favorable tax system in place for companies with headquarters-type activities—the so-called coordination center regime.
28 Jul 2005
Recent Developments Regarding EC Tax Directives (an Alternative to Treaties in Europe)
In 1990, Directive 90/435 was promulgated, introducing a streamlined system of taxation for intra-EC dividends, with the objective of exempting from withholding dividends and other profit distributions paid by subsidiaries to their qualified parent companies.
United States
14 Sep 2004
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