Whether they are set up to bring together a certain number of investors, to optimize acquisitions for tax purposes or to organize specific family situations, holding companies are a major player in the legal and financial landscape of our country.
On the occasion of this conference, Denis-Emmanuel PHILIPPE invites you to examine the news relating to the tax regime for holding companies as well as the measures provided for by the preliminary draft law relating to the tax reform announced and currently on the table of the government.
Regarding news relating to the holding company regime, the following subjects will be discussed in particular:
Recent advance rulings on the one-year holding period in the presence of successive sales of shares
The risks of rejection of the exemption from withholding tax in the event of distribution of dividends by a Belgian holding company to its foreign parent company – Overview of recent case law
The new rules limiting the deduction of borrowing costs (30% EBITDA / €3m): what concrete impact on holding companies?
“Belgian-style” tax consolidation (intra-group transfer):
What are the possibilities for tax optimization between a holding company and its subsidiaries?
Is the impossibility of charging the intra-group transfer to the RDTs contrary to European law?
Regarding the tax reform project, the following measures will be analysed:
The addition of a condition of financial immobilization:
What is a financial fixed asset?
Can shares in a listed company be considered as such?
What is the impact of this measure for asset holding companies?
What are the risks associated with an accounting reclassification of cash investments as financial fixed assets? Tax abuse (article 344, §1 of the CIR92)?
The abolition of the RDT SICAV system
Collateral damage of the reform: the abolition of the preferential regime (non-application of the minimum participation and holding conditions) applicable to investment companies and their shareholders: what impact for master-feeder structures and for private pricafs?
The RDT regime: when the deduction turns into an exemption... What are the possibilities for tax optimization (particularly in terms of intra-group transfers)?
This training is aimed at many practitioners and in particular, lawyers, jurists, accountants and tax advisers, but also all professionals in the tax and financial sector active in Belgium and Luxembourg.
Where does it take place?
RAMADA BY WYNDHAM BRUSSELS WOLUWÉ
Avenue des Pléiades 67
1200 Woluwe-Saint-Lambert
Bruxelles
Belgium
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