Mark Melzer

A project we have been working on for the last two years or so: the establishment of our Mazars Financial Services Transfer Pricing Center of Excellence. Check out our website in the link and experience the value added services and solutions that this can bring to your organization #mazars #financialservices #banking #capitalmarkets #insurance #transferpricing #tax #london

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📢 Deadline Belgian Pillar Two Notification Form extended till 𝟭𝟲 𝗦𝗲𝗽𝘁𝗲𝗺𝗯𝗲𝗿 𝟮𝟬𝟮𝟰 ! 🛑 Note: This administrative tolerance for the extended deadline applies only to groups that will not make Belgian advance payments for the 2024 QDMTT and/or IIR. For those planning to make advance payments for the Belgian QDMTT and IIR in 2024, the original deadline remains in effect. 💼 𝗡𝗲𝗲𝗱 𝗔𝘀𝘀𝗶𝘀𝘁𝗮𝗻𝗰𝗲? If you have questions or require support with the Belgian Pillar Two Notification Form, please reach out to the EY contact person on this alert. #PillarTwo #QDMTT #FPSFinance

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📊 Budget Day 2025 Update: Key Tax Changes You Need to Know! Today marks an important moment for businesses in the Netherlands. On this Budget Day, the government published the tax plans for 2025. One significant change to highlight is the adjustment in the interest deduction limitation rule, commonly known as the ‘earnings stripping rule.’ 🔹 What’s Changing? The permissible limit for deductible excess interest expenses will increase from 20% to 25% of the adjusted Dutch taxable profit (EBITDA for tax purposes). This adjustment offers a more lenient approach towards the financing costs businesses can deduct. 🔹 Thresholds and Conditions The earnings stripping rule will maintain its threshold where excess interest expenses up to EUR 1,000,000 are not restricted. Additionally, any excess can still be carried forward without limitation, providing flexibility for future fiscal years. 🔹 Special Focus on Real Estate A notable stipulation in the new tax plan targets real estate businesses. If a taxpayer’s adjusted property mainly consists of immovable property for at least half of the year and is made available to someone other than related entities or associated persons, these changes will particularly impact how these assets are taxed. 🔍 Implications These changes could have profound implications for financing strategies and tax liabilities, particularly for businesses heavily invested in real estate or those with significant financing costs. 💬 I’m keen to hear your thoughts on how these changes will impact our industry and your business. Let’s discuss below! #NetherlandsTax #BudgetDay2025 #Finance #BusinessTaxation

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Important upcoming BEPS filing requirment. Multinationals subject to Pillar Two, having either a Belgian ultimate parent entity, or one (or more) Belgian constituent entity(ies), are required to file a Pillar Two Notification in Belgium by 13 July 2024 (or 30 days following the start of the financial reporting year for the MNE group if this is later). The volume of information required to be disclosed in the P2 Notification Form is substantial (requires entity P2 qualification understanding) and is detailed in the attached alerts.

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📣 Belgium further expands its transfer pricing documentation and filing requirements 📣 📅 On 15 July 2024, Belgium has issued new Royal Decrees, updating the transfer pricing documentation requirements for qualifying taxpayers. 📝 The new Royal Decrees, introduce additional information requirements for both the Local and Master File Forms. They mandate the submission of transfer pricing documentation, framework agreements, or model contracts. For country-by-country notifications, the submission of Form 275.CBC.NOT is now required also in case of termination of the notification obligation. 📊 The new model for the forms will apply to financial years starting on 1 January 2025. Know more by reading our latest Transfer Pricing alert! https://lnkd.in/eF8PsXTA #EY #EYBelgium #BelgiumTax #Tax #TransferPricing #BEPS #OECD #TaxCompliance

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On 🗓️ 21 June 2024, the Economic and Financial Affairs Council (#ECOFIN), under the Belgian presidency, faced another setback as the 27 EU member states failed to reach an agreement on the VAT in the Digital Age (#ViDA) proposal. Despite this, all member states commended the Belgian presidency for its hard work to reach a consensus 💪🏻. The baton will now be passed to Hungary, which will assume the EU Council presidency as of July. A key takeaway is the consensus among member states on the DRR pillar! The only veto came from Estonia, concerning the new deemed supplier regime, which imposes VAT collection responsibilities on platforms facilitating short-term accommodation rentals and passenger transport. Read the full alert below ⬇️ #VIDA #Einvoicing #Ereporting #DRR #ECOFIN #Deloitte

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Pillar Two update - The Belgian tax authorities published today a message that they will provide an administrative tolerance until 16 September for the notification form for Pillar Two for entities that will not carry out advance payments in 2024 for (Belgian) domestic top-up tax or IIR. For groups that wish to carry out advance payments in 2024, the deadline remains 13 July. https://lnkd.in/eYPP54DE #Deloitte #PillarTwo

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I had the pleasure to discuss the latest #Pillar2 developments in Belgium together with my coleague Pieter Deré. The pillar 2 advance payment system for any DMTT or IIR tax liability in Belgium is now live. There are however some important attention points. Thanks Stephanie Soong from Tax Notes for working together on this article! #pwc #pwcbelgium #tax #internationaltax

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Important #tax update: Belgium has introduced new content requirements for the #TransferPricing forms (Local File Form, Master File Form, and CbCR Notification Form) through a Royal Decree dated 14 July 2024. These changes will take effect for financial years starting on or after 1 January 2025, requiring companies to disclose and file substantially more information than before. Read more: https://bit.ly/4ca6PHa #KPMGBelgium #OECD #TaxRegulations

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🇪🇺The #EuropeanCommission has issued a letter of formal notice to the Netherlands for not extending the #Dutch #tax #levy #reduction scheme to foreign investment funds that are comparable to Dutch investment funds (the so-called “#afdrachtvermindering”). 🇳🇱Dutch law allows a reduction in the dividend tax paid by investment funds on dividends received from companies in which they hold shares. This is achieved by offsetting the tax paid by the Dutch company distributing the dividends. 🌎Unlike Dutch investment funds, foreign investment funds cannot offset the dividend tax paid by Dutch companies on dividends they distribute and later redistribute to their own investors. In the Commission’s view, this creates a #disadvantage for #foreign #investment #funds, making it less attractive for them to offer services to Dutch investors & to invest in shares of Dutch resident companies. Three key points: 1️⃣The formal notice is based on the #free #movement of #capital: it therefore also concerns #non-#EU #funds (not only EU funds!). 2️⃣The Netherlands has 2 months to convince the Commission that there is a valid reason not to extend the afdrachtvermindering to comparable foreign funds (including the summer vacation???) 3️⃣This case may look similar to the #Deka case (C‑156/17), though that case involved the old system of the refund of tax withheld on dividends. PwC Nederland #KnowledgeCentre

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[#LetsTalkGlobalTax] Under the Dutch CIT rules, profits and capital gains related to participations are exempt for tax purposes. This also limits the deductibility of costs that directly relate to the acquisition or sale of such a participation. Thierry Boonstra, M&A Director, and Marco Hulsman, M&A Tax Advisor, Mazars in Nederland, provide a breakdown of this legal principle: http://maza.rs/6042Y8Ymg

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On 1 October 2024, the Dutch tax authorities published a knowledge group position (Kennisgroepstandpunt) addressing the tax classification of certain foreign entities under the new Dutch entity classification rules, effective from 1 January 2025. This is highly relevant for all foreign vehicles investing in Dutch assets, for example foreign legal entities investing in Dutch real estate directly, such as French SCPIs. Interested in the implications for you? Please see: https://lnkd.in/edEq4pU2 Questions? Please contact Arthur Smeijer or Emilie Meeùs. #atlasfiscalisten #realestate #SCPI #legalentities #svalneratlasgroup #wtsglobal #vastgoed

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🔔 UK Tax Updates for Private Equity 🔔 The Government’s recent announcements have paved the way for expected tax increases and changes to carried interest. My colleague, Lewin Higgins-Green, explores the tax implications for PE firms in this month’s WTS Global Financial Services Newsletter. In addition, PE funds are also being impacted by a recent change in HMRC’s approach and guidance on UK LLP tax structures. Angus Wilson and Lewin have explored the impact for PE firms and their partners. Link below to the Newsletter. Please do reach out if you’d like to discuss any of these issues in more detail. #PrivateEquity #Tax #CarriedInterest #PE

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For 2 years in a row scoring full marks, Philips has been awarded the winner of 2024 Tax Transparency benchmark by #VBDO.  The expert jury appointed by VBDO has especially complimented for publishing a full Country Activity and Tax Report, including a narrative linking Philips’ business and activities to taxation. Read the report : @https://lnkd.in/eS4i-fWi Tax is an integral part of Philips’ Environmental, Social and Governance (#ESG) commitments. We consider our tax payments as a contribution to the communities in which we operate, as part of our social value creation. https://lnkd.in/e8UbeTPm Miki Brooks Philips De Vereniging van Beleggers voor Duurzame Ontwikkeling (VBDO)

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The Dutch Tax plan 2025 that was published today includes several proposals that are relevant for international companies. The key topics are discussed in below alert.

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#BoardMembers, CFOs, CROs, and financial leaders - stay ahead with our essential annual update on financial reporting, tax, and regulatory matters. Gain insights from #KPMGBelgium’s top experts on the latest IFRS standards, tax changes, and critical Belgian and European legal developments impacting your role. Register for our #BLCBelgium webinar: https://bit.ly/3AuWjxy

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On 24 September 2024 tax practitioners from business and consultancy had an informal meeting in Rotterdam to discuss what is next after the silent collapse of Pillar One. The exercise resulted in an exploration of #developments, culminating in a call for some renewed thinking on company #tax reform by seeking a tax-equilibrium through competition rather than through coordination, since this is how the world seems to be working. One of the participants, Maarten Floris de Wilde, wrote a blog about the meeting for the Kluwer International Tax Blog! #taxlaw #taxreform #pillarone

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Importing goods in the Netherlands as a non-Dutch company triggers a VAT-registration so that the goods can be cleared and following sales can be reported. When a non-Dutch company appoints a fiscal representative in the Netherlands, it can make use of the same benefits as a Dutch company; such as the Article 23-License. This blog covers all the info you need to appoint a fiscal representative & to apply for the article 23-license.

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Important #tax update: Belgium has introduced new content requirements for the #TransferPricing forms (Local File Form, Master File Form, and CbCR Notification Form) through a Royal Decree dated 14 July 2024. These changes will take effect for financial years starting on or after 1 January 2025, requiring companies to disclose and file substantially more information than before. Read more: https://bit.ly/4ca6PHa #KPMGBelgium #OECD #TaxRegulations

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