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New tax treaty between France and Belgium – Transfer of tax residence and sale of shares – The tax administration may follow you

The currently applicable double tax treaty between France and Belgium was concluded in 1964 and has been amended many times until 2009. After several years of negotiations, Belgium and France finally signed a new double tax treaty (hereafter, the “new Treaty”). The 1964 Treaty remains applicable until the new Treaty has been ratified by the French and Belgian parliaments. Assuming the ratification occurs in 2022,...

Tax challenges arising from digitalisation OECD - public comments

On 18 February 2022, as part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD invited public comments on the Draft Rules for Tax Base Determinations under Pillar One Amount A to assist members in further refining and finalising the relevant rules. The OECD...

Tax Policy and Gender Equality :- 22 countries have implemented specific tax reforms to improve gender equity.

Promoting gender equality, as reflected in the Universal Declaration of Human Rights and the Sustainable Development Goals, is a human rights objective for many governments, including in G20 and OECD countries.Improving gender equality is not only an issue of fairness but can also produce a significant economic dividend. Working towards more inclusive economies in which women participate fully is important for economic growth and, in...

OECD Tax and Development Days 2022

Following the success of its first edition in January 2021, the OECD is pleased to host the Second Tax and Development Days on 16-17 February 2022. Due to the ongoing health crisis, the event will be held virtually on Zoom. About All members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) and key stakeholders are invited to participate, with all sessions also open to...

National legislation requiring Spanish tax residents to declare their overseas assets or rights is contrary to EU law

The restrictions on the free movement of capital imposed by that legislation are disproportionate On the 15 February 2017, the Commission issued a reasoned opinion in which it found that certain aspects of the requirement for Spanish tax residents to declare overseas assets or rights [1] by means of a form entitled ‘Form 720’ were incompatible with EU law. According to the Commission, the consequences...

New tax treaty between France and Belgium - Do you own a French real estate property? Nothing is set in stone

Tax experts from Mazars Société d’Avocats (France) and CAZIMIR (Belgium) have analyzed the potential impacts of the changes of the new Treaty for their clients (wealthy individuals and owners of family businesses). In this article, we will focus on the situation of individuals residing in Belgium who hold real estate property located in France. Please note that our contributions only look at the situation from...

Transfer Pricing Guidelines ...

The OECD releases the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. In a global economy where multinational entreprises (NMEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their juridiction ant that the tax base reported bij MNEs in their country reflects th economic activity undertaken...

Tunisia commits to start automatic exchange by 2024

​Tunisia has committed to implement the international Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by 2024. This commitment makes Tunisia the 121st Global Forum member to commit to start AEOI by a specific date, and the tenth African country to do so.​“Tunisia’s commitment to the automatic exchange of information on financial accounts is a further essential step in the fight...

Global Tax agreement : OECD publishes model rules for domestic implementation of 15% global minimum tax

The OECD has published detailed “Pillar Two” rules that will help governments drive forward the implementation of the landmark 2021 tax agreement, ensuring a global minimum 15% tax rate for Multinational Enterprises from 2023. Download the report (PDF) The Pillar Two model rules provide governments a precise template for taking forward the two-pillar solution to address the tax challenges arising from digitalisation and globalisation of...

OECD - Fighting Tax Crime – The Ten Global Principles, Second Edition

​First published in 2017, Fighting Tax Crime - The Ten Global Principles is the first comprehensive guide to fighting tax crimes. It sets out ten essential principles covering the legal, institutional, administrative, and operational aspects necessary for developing an efficient and effective system for identifying, investigating and prosecuting tax crimes, while respecting the rights of accused taxpayers. This second edition addresses new challenges, such as...

G20 summit : new rules for a more stable and fairer international tax system ...

G20 leaders met for a two-day summit hosted by the Italian G20 presidency in Rome on 30 and 31 October 2021. At the end of two days of working sessions and side events, the G20 Leaders adopted the G20 Rome Leaders Declaration. This document is the final outcome of an intense year of negotiations and events organized in the framework of the Italian G20 Presidency.Main...

A ground-breaking tax deal for the digital age

OECD : Major reform of the international Tax system finalised on the 8 october will ensure that Multinational Entreprises will be subject to a minimum 15% tax rate from 2023 The landmark deal, agreed by 136 countries and jurisdictions representing more than 90% of global GDP, will also reallocate more than USD 125 billion of profits from around 100 of the world’s largest and most...

Tax administrations continue to accelerate their digital transformation ...

Tax administrations are investing significant resources in the development of e-services and digital solutions and are embracing opportunities for fast tracking digital transformation to improve their services, reduce burdens, and improve tax compliance, according to a new OECD report. This ninth edition of the OECD's Tax Administration Series provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging...

Disclosed/Undisclosed Agent in the EU VAT: When Is an Intermediary Acting in Its Own Name ?

In the issue 5, 2021 of the International VAT Monitor, I summarize various arguments raised in the Case C-695/20 Fenix International Ltd pending before the Court of Justice of the European Union. Is such e-platform a "disclosed agent" only because the final customer knows the name of the actual supplier who also determines the amount of the subscription fee ? The answer to...

New OECD data highlights the importance of the international tax reform discussions

New data, released on 27/07/2021 underlines the importance of the two-pillar plan being advanced by over 130 members of the OECD/G20 Inclusive Framework on BEPS to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate. Working with over 100 countries, the OECD is a global policy forum that promotes policies to improve the economic and social...

Accountants – REACT now and help SMEs adapt to new VAT e-commerce rules

The changes to the EU e-commerce rules will take effect from 1 July 2021. This factsheet provides a high-level summary of the main changes and how accountants can support their SME clients. Time is of the essence. The rule changes will greatly affect SMEs active in e-commerce. Accountants should research the changes as soon as possible to be able to inform and support their clients. We...

For tax and customs professionals across the EU ...

This European Commission’s new Learning Portal offers opportunities for customs and tax professionals to build, upscale or share profession-relevant knowledge and expertise through initiatives ranging from educational online learning to the organisation and hosting of multiple learning events in online and presence formats. Based on sharing of best practice, cross-country collaboration and tailored learning, this interactive training opportunity supports continuous skills & knowledge building for...

New oecd report -Taxing Wages 2021 : and the winner is Belgium ...

Taxing Wages 2021 shows that declining household incomes coupled with tax reforms linked to the pandemic are driving widespread declines in effective taxes on wages across the OECD. Between 2019 and 2020, the tax wedge for this household type decreased in 31 countries, and rose in only 6. It decreased by more than 1 percentage point in 16 countries. The largest decreases were in Lithuania,...

Save the date : 20 April, 16.00 CET

How can green taxation help achieve the EU’s ambitious climate goals? Join the #EUGreenTaxation online event to discuss how to make our tax systems greener The European Union has set out ambitious targets to tackle climate change and foster a cleaner environment, with a view to becoming a climate-neutral continent by 2050. Environmental taxation can play a positive and active role in achieving these...

Call for contributions: sustainable tax systems

Accountancy Europe (AE) is calling for thought leaders in taxation to share their views on the changes necessary to make tax systems fit for the future. Our current tax systems are struggling to keep up with new business models, ageing demographics, and mobile taxpayers. The coronavirus crisis, climate urgency and social stresses have exacerbated these difficulties. Accountancy Europe believes now is the time...