Implementing Pillar One & Pillar Two

Building upon work conducted for several years on how to adapt the international tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework proposes a two-pillar overhaul of the existing system as from 2023/2024. While the main policy features are agreed, detailed model rules and draft multilateral conventions are due to be released over 2022.

Tax directors and their teams can already model the impact, prepare for the additional tax compliance burden and assess opportunities for manageable restructurings to mitigate the increased complexity.

Substance & Tax Law

In recent years tax authorities have placed more emphasis on combatting the use of abusive and aggressive tax structures by companies operating across borders, to ensure fair taxation. The EU and OECD have provided tax authorities with various instruments such as the Anti-Tax Avoidance Directive (ATAD) and the Multilateral Instrument. The judgements handed down by the CJEU on the Danish cases have also set an important precedent.

However, since entities with no minimal substance and economic activity are supposedly still used for improper tax purposes, the European Commission recently issued a new proposal (ATAD 3). It is highly recommended that taxpayers already assess the possible impact of the proposal and consider opportunities for strengthening their local footprint and/or restructuring.

Digital Economy

Digital transformation is all about using the latest technology to improve your business model. Digital technology creates new business opportunities which in turn creates a whole new range of tax and legal challenges such as contracting, data protection, privacy questions, intellectual property, consumer protection and competition issues.

The speed at which digital technology has become an integral part of our daily lives has overtaken most legislative processes. In recent years, the European Union, Member-States and international legislative bodies have therefore increased their regulatory efforts.


The anti-hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD2) aim to prevent situations of a double deduction and a deduction without a corresponding inclusion of the income at the level of the recipient resulting from a hybrid mismat

Budget Day 2024

On this page our legal and tax experts provide compelling insights in the lead up to Budget Day and their initial analysis directly after the budget plan is presented.


The implications of the COVID-19 pandemic reach across borders, industries, and legal disciplines. That is why Loyens & Loeff has set up dedicated expert teams - to offer you an integrated answer to all your legal and tax questions related to the cor

Corporate Investigations, Compliance & Defence

Recent developments, such as international treaties to combat (cross border) corruption, money laundering and the financing of terrorism and more sophisticated international cooperation between (tax) authorities are just a few examples of the growing

Digital Economy Tax

Politically it is clear that both the EU and other jurisdictions wants to levy more tax from ‘digital companies’. Technically, the current international tax framework does not facilitate this. Fundamental changes seem to be required to achieve the po

Multilateral Instrument

The multilateral instrument (MLI) implements the treaty related anti-tax avoidance measures of the BEPS project in bilateral tax treaties.

Reform of property law

In the Book 3 "Goods" of the Civil Code the main goal of the legislator was to better structure, modernise and integrate the law on goods into a single code. Moreover, the new law on goods had to be functional, useful and flexible.

Reform of contract law in Belgium

The new Book 5 of the Civil Code will enter into force on 1 January 2023 and contains legal provisions on general Belgian contract law. It is a legal development which will not go unnoticed, and which will have a significant impact on contractual rel

New Criminal Code in Belgium

The Belgian Parliament has approved draft bills recasting the first and second books of the Belgian criminal code. This reform aims to achieve several objectives: making the criminal code clearer, enhancing accessibility, and introducing significant