Belgium In International Tax Planning

This book focuses on commercial and company law and corporate income tax. It provides a systematic and comprehensive overview of the current tax planning opportunities that exist in Belgium. After some essential legal knowledge of Belgium, the chapters consider the Belgian tax regime, special features of the Belgian tax system, specific anti-avoidance provisions and international tax planning, tax incentives, special tax regimes, and tax planning opportunities (including the tax treaties with Hong Kong, the USA and the UAE).

This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.

Selected Issues

This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.

This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.

If investment in the EEC countries has been the major preoccupation of the international business community in the 1960's, contracting in the Arab states seems to become one of the major trends of the 1970's. The need for multicountry business and tax information was felt simultane ously. Language difficulties, scarcity of legal and other sources, distance and, most of all, the novelty of business expansion in this direction made such information still more necessary than in the European or inter American setting. A few symposiums were held, corporate and tax laws were translated, research studies were initiated, among which the book of Mr and Mrs SIIILLING on Doing Business in Saudi Arabia and the Arab Gulf States, a rich mine of general business information. I was therefore very pleased when Mrs CLERIN, completing her tax studies at Ecole Superieure des Sciences Fiscales in Brussels, mentioned that she was going to live in the Middle East, had the opportunity to work with a well-known international accounting firm and proposed to focus her final dissertation at the School on the tax planning of operations in Arab countries. She devoted months of research to the study of sources both in Middle East and in industrial ized Western countries, to come up with a true planning study, clear, readable and practical. The description of the tax and corporate structure of the operating territories will be found in the first half of the book.

This book is a concise foreign tax reference tool for the practitioner who needs quick answers to basic corporate and individual tax questions.

This is the second edition of Rest in Peace, a Guide to Wills and Inheritance tax in Belgium. After four years an update was long overdue. There have been numerous changes, in Belgium and abroad, with new inheritance tax rates and rules, the European Succession Regulation, etc... Estate planning is not just about drawing up a will and finding ways to minimise taxes. It is essentially about peace of mind. Smart estate planning can be complex, and if you need to plan across borders, that can be quite daunting. This book is for you if you live in Belgium and you want to understand how the rules work and how you draw up a valid will; you live in Belgium and you want to plan your estate in an efficient manner; you want to know what happens when you inherit from your parents in Greece; your children live in other countries; you have property in other countries; you have investments and bank accounts in other countries; your parents have set up a trust for your benefit. This book is also for you if you do not live in Belgium and you own property in Belgium; you stand to inherit from someone who died in Belgium and you need to understand whether you should accept or waive the inheritance; you consider retiring in Belgium; you are an official of an international institution and you live temporarily in Belgium; you plan your estate and one or more of your children live in Belgium. This book can help you make sound decisions that could help your loved ones when you are gone. Table of contents for a preview see https: //issuu.com/taxation.be/docs/rest_in_peace_2017 Dealing with death Who inherits what? Last will and testament Forced heirship Usufruct Community property Inheritance Tax Cross border successions The art of estate planning Plan in your will Plan by donating Change your marriage contract Plan with life insurance Planning by contract Trusts and foundations Plan your life Practical planning Annexes