Tax news Case-law: Application of the general anti-abuse rule (art. 344,§1 ITC, GAAR) : denial of domestic foreign tax credit on royalties received by a Belgian SCS (Hybrid) (Trib. Liège, 21 octobre 2024) 21 October, 2025
Tax news Recent case-law (Johnson Controls case): (i) EU principle of prohibition of abuse – (ii) Transfer pricing (Court of First Instance of Leuven, 6 June 2025 19 August, 2025
Tax news New reporting obligation of certain share deals (SPA) under the preliminary draft bill with respect to the new capital gains tax Will it come through? 7 July, 2025
Uncategorized Capital gains on funds units : interaction between art. 19bis ITC (Reynders tax) and the new 10% capital gains tax 2 July, 2025
Tax news Not so easy for Luxembourg SICAV to successfully rely on the Belgium-Luxembourg DTT… 28 May, 2025
Tax news Participation exemption regime : new condition of financial fixed asset. Why does the size of the holding company matter? Is dividend income considered as turnover? Opinion of the Council of State 19 May, 2025