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In brief

Since the decisions of the European Court of Justice in the so-called “Danish cases”, passive income streams are being scrutinized more than ever across Europe. This is not different in Belgium, where we have seen a substantial increase in tax audits focusing on passive income streams where withholding tax is being claimed also in the framework of business-driven structures.

During this webinar, we gave a recap of the beneficial ownership concept, as interpreted and applied by the OECD and the European Court of Justice, and the interrelation of the beneficial ownership concept with treaty abuse. We also touched upon the first case law in Belgium and in other EU countries on this topic. In this framework, we moreover discussed our experience with respect to beneficial ownership challenges by the Belgian tax authorities and our recommendations to reduce such challenges.

SpeakersAlain HuygheJulie Permeke and Marie Krug.

Do not hesitate to reach out to Isabelle Reynertz if you would like to obtain the recording of this webinar.

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Belgium: Ahead of Tax – Wage tax incentives – new developments and audit wave: what you need to know (Webinar)

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Alain Huyghe is a partner in the Tax Practice Group of the Brussels office. He joined Baker McKenzie in 1986 and became partner in 1994. Alain has been mentioned consistently over the past 25 years as a leading tax lawyer in Belgium in publications such as the International Tax Review, Chambers and The European Legal 500.


Julie Permeke is a partner in the Tax Practice Group of the Brussels office. She joined Baker McKenzie in 2016 after several years of experience as a tax lawyer in other well reputed Benelux law firms. She also works as a voluntary researcher in the tax department of the Free University of Brussels (VUB). Julie has been listed as a recommended tax lawyer in Legal 500.


Marie Krug is an Associate in Baker McKenzie's Brussels office.

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