Base Erosion and Profit Shifting (BEPS)
G-20, OECD and the EU have heavily increased the number of initiatives that discourage Base Erosion and Profit Shifting (BEPS).
The introduction of CFC legislation in Belgium
Year-End Tax Bulletin 2017
MLI Matching Overview
Launch of multilateral treaty (MLI) to implement BEPS measures
Our expert BEPS team can help you
Internationally operating companies therefore need high-end strategies to create an effective tax structure. Such strategies need to consider all regulatory developments and acknowledge the change in the international tax climate. Our expert BEPS team can help you to design an international tax strategy and implement optimal solutions.
Your BEPS team: on top of the latest regulatory developments
New regulations are deployed at a rapid pace. This means that you need a team that is on top of the latest developments. Our multidisciplinary team of experts monitors the following developments closely:
- Fundamental changes to transfer pricing rules;
- Limitation of base erosion via interest deductions and other financial payments;
- The EU’s Anti-Tax Avoidance Package / Directive (ATAD);
- Transparency measures (country-by-country reporting, exchange of tax rulings between EU Member States, mandatory disclosure rules, the introduction of the UBO register, etc.);
- Changes to double tax treaties and the multilateral instrument (MLI);
- State aid issues;
- Proposals for the taxation in the Digital Economy
- Proposals for an EU Common Corporate Tax Base (CCTB) and an EU Common Consolidated Corporate Tax Base (CCCTB).
Our advice will always weigh the impact of public opinion on your reputation, while tackling the major tax hurdles. Our BEPS team cooperates with our competition lawyers, state aid/EU tax law experts, litigators and transfer pricing experts, in order to provide you with the best integrated solution for your company.
Our services
We advise on and review the impact for multinationals of:
- The various BEPS measures;
- Fundamental changes to transfer pricing rules;
- Limitation of base erosion via interest deductions and other financial payments;
- The EU’s Anti-Tax Avoidance Package / Directive (ATAD);
- Transparency measures (country-by-country reporting, exchange of tax rulings between EU Member States, mandatory disclosure rules, the introduction of the UBO register, etc);
- The General Anti-Avoidance Rule (GAAR);
- Changes to the double tax treaties;
- The multilateral instrument (MLI);
- Holding structures;
- Group financing;
- IP structures;
- Hybrid mismatches.
- Proposals for the taxation in the Digital Economy
- Proposals for an EU Common Corporate Tax Base (CCTB) and for an EU Common (Consolidated) Corporate Tax Base (C(C)CTB)
Natalie Reypens
Partner Attorney at LawNatalie Reypens is a member of the Loyens & Loeff International Tax Services Practice Group and heads the Belgian Transfer Pricing Team. She is a partner in our Brussels office. She focuses on corporate and international tax law.
T: +32 2 743 43 37 E: natalie.reypens@loyensloeff.com
Caroline Docclo
Of Counsel Attorney at LawCaroline Docclo is Of Counsel to the Loyens & Loeff Brussels office. She is a member of the Loyens & Loeff International Tax Services Practice Group and of the Tax Controversy and Litigation Team. She has a broad practice in counselling and litigation in tax matters.
T: +32 2 700 10 15 E: caroline.docclo@loyensloeff.com
Marc Dhaene
Partner Attorney at LawMarc Dhaene is a member of the International Tax Services Practice Group and of the Tax Controversy and Litigation Team. His expertise covers a broad range of international and domestic corporate tax issues.
T: +32 2 743 43 22 E: marc.dhaene@loyensloeff.com
Christian Chéruy
Attorney at LawChristian Chéruy is a member of our International Tax Services Practice Group in Brussels. He is also part of the Belgian Tax Controversy and Litigation Team. Christian is a former local managing partner and non-executive Chairman of the Loyens & Loeff Benelux Board.
T: +32 2 743 43 03 E: christian.cheruy@loyensloeff.com
Nicolas Bertrand
Partner Attorney at LawNicolas Bertrand is a partner in our Brussels office. He co-heads the Loyens & Loeff Family Owned Business & Private Wealth Practice Group in Belgium.
T: +32 2 773 23 46 E: nicolas.bertrand@loyensloeff.com