Month: May 2026

The reason is clear. Although the European Union benefits from an internal market, businesses still face, in practice, diverging national rules, formalities and administrative procedures. For start-ups, scale-ups, investors and international groups, this fragmentation remains a barrier to growth, financing and cross-border expansion. The EU Inc. aims to provide a pragmatic response to these challenges.…

The EU transposed these rules through Council Directive (EU) 2022/2523 of 14 December 2022. Belgium implemented the Directive by way of the Law of 19 December 2023 (the “Belgian Pillar Two Law”), as amended by the Law of 12 May 2024. The rules apply to MNE groups and large-scale domestic groups with consolidated annual revenues…

This new mechanism, outlined in a brochure published by the Belgian Federal Public Service Finance (“FPS Finance”) on 22 April, has become the central instrument governing the financial relationship between taxable persons and the tax authorities. While the underlying principles remain unchanged for businesses that comply with their obligations, the practical implications for monitoring payments,…

A vendor due diligence essentially means that a transferor or seller, before the actual sale process is initiated, even before the company is brought to market, conducts an internal review of the company in order to identify potential issues or deal breakers (matters that could affect the purchase price or result in extensive warranty obligations)…

1. A “Disguised Right of Pre-emption” in Practice Although this does not constitute a classic right of pre-emption, whereby the tenant simply steps into the position of a third-party purchaser, the system does require the seller to first submit a concrete and complete offer to sell to the tenant. In that sense, this right of…

1. The ATAD framework and the initial choice of Belgium The ATAD requires Member States to implement CFC rules designed to include, under certain conditions, the undistributed profits of low-taxed subsidiaries in the tax base of the resident parent company. Two models are available for determining the income to be included: Model A (“entity-based”) and…

Adopted on 28 February 2024, the ECGT Directive strengthens existing EU consumer protection rules to combat misleading sustainability claims and ensure that information provided to consumers is accurate, transparent and verifiable. The Directive had to be transposed into Belgian law by 27 March 2026, with application from 27 September 2026. As of April 2026, Belgium…

A. Former and New Expatriate Regimes The former expatriate regime was based exclusively on the Circular of 8 August 1983. By virtue of the Programme Law of 27 December 2021, the former “administrative” regime has been replaced by a new “statutory” regime (please refer to this article for more information). Pursuant to a transitional provision,…