WTax’s Post

Why we jump to Retrospective point when the objective and scope of amendment itself is not 100% clear, clarified, debated and tested. One shouldnt assume PPT is principle test to qualify for tax treaties benefits, rather it should be tested selectively for specific cases, otherwise the fundamental objectives of tax treaties could become questionable. PPT test must read with the limitation of benefits clause. Due weightage should be given to specific words such as 'direct' or 'indirect' or both 'direct and indirect' "benefits" etc agreed between the respective treaty partners to avoid the 'chaos'. Lastly PPT is not new concept, so question of being prospective or retrospective is not that relevant. My personal views. https://lnkd.in/dgg6tG3u

Dear tax lovers, Update for Belgian Companies with Foreign Investments! Recent changes to Belgian CFC (Controlled Foreign Corporation) legislation could lead to increased tax burdens for your investments. If your Belgian company controls a foreign entity with an effective tax rate under 12.5% (based on Belgian tax rules), you might face additional taxes on the undistributed passive income of that foreign entity. Read more in our latest article:

Public focus on the UN-OECD dynamic is trending ahead of tomorrow's (April 26) meeting of the UN Ad Hoc Committee on a framework convention for international tax cooperation. https://lnkd.in/eJMAsD7Y

Update for Belgian Companies with Foreign Investments! Recent changes to Belgian CFC (Controlled Foreign Corporation) legislation could lead to increased tax burdens for your investments. If your Belgian company controls a foreign entity with an effective tax rate under 12.5% (based on Belgian tax rules), you might face additional taxes on the undistributed passive income of that foreign entity. Read more in our latest article:

Update for Belgian Companies with Foreign Investments! Recent changes to Belgian CFC (Controlled Foreign Corporation) legislation could lead to increased tax burdens for your investments. If your Belgian company controls a foreign entity with an effective tax rate under 12.5% (based on Belgian tax rules), you might face additional taxes on the undistributed passive income of that foreign entity. Read more in our latest article:

GLOBAL MINIMUN TAX International Monetary Fund Pillar Two rules of the Inclusive Framework agreement on a minimum corporate tax (known as ‘Global Anti-Base Erosion Rules’, for short GloBE) have important implications for the design of the corporate income tax. This chapter discusses these implications particularly from the perspective of low-tax jurisdictions. It argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. https://lnkd.in/dFpB_-5F

🌍 A Major Step Towards Fairer Global Taxation 🌍 Yesterday, the international community made a significant advancement in international tax reform with the signing of a multilateral treaty to implement the Pillar Two Subject to Tax Rule (STTR). 📝 ✨ This rule aims to ensure a minimum level of taxation on cross-border payments, particularly benefiting developing countries by safeguarding their tax bases. 🌱🌏 Nine jurisdictions signed this treaty, allowing early adopters to move quickly in implementing the STTR. 🚀 This is a critical tool for addressing the issues of Base Erosion and Profit Shifting (BEPS), ensuring that multinationals contribute their fair share of taxes. 💼💸💪 The STTR, which complements other rules within the global tax framework, gives countries the right to "tax back" income taxed below the 9% threshold, providing a safeguard against harmful tax competition. ⚖️🌐 More than 70 developing nations can now request the inclusion of STTR in their tax agreements. 🌟 This achievement represents a major milestone in securing a more stable and equitable global tax landscape. 🌈 By curbing profit shifting and enhancing tax fairness, governments worldwide can generate much-needed revenues to fund their essential services. 💰💖 For more details, visit:👇 https://oe.cd/sttr-mli https://oe.cd/5Hu #GlobalTax #TaxFairness #STTR #PillarTwo #OECD #TaxReform #InternationalTaxation

Update for Belgian Companies with Foreign Investments! Recent changes to Belgian CFC (Controlled Foreign Corporation) legislation could lead to increased tax burdens for your investments. If your Belgian company controls a foreign entity with an effective tax rate under 12.5% (based on Belgian tax rules), you might face additional taxes on the undistributed passive income of that foreign entity. Read more in our latest article:

What effect will President Trump's inauguration have on the OECD's two-pillar international tax proposal? Last week OECD Tax released more guidance on aspects of Pillar Two as the deal continues to progress slowly towards implementation. However, in his inauguration speech President Trump commented “America will no longer be beholden to foreign organizations for our national tax policy, which punishes American businesses." Could this be a sign that the US will abandon the deal? American's participation will be a major issue in international tax this year. Watch this space. #internationaltax #BEPS #trump https://lnkd.in/g6WNuw-F

Update for Belgian Companies with Foreign Investments! Recent changes to Belgian CFC (Controlled Foreign Corporation) legislation could lead to increased tax burdens for your investments. If your Belgian company controls a foreign entity with an effective tax rate under 12.5% (based on Belgian tax rules), you might face additional taxes on the undistributed passive income of that foreign entity. Read more in our latest article: