13 of November 2019

Agoria - FEB Tax Seminar

“OECD activities involving the taxation of the digitalising economy:
What should we expect and what will be the consequences?
How can we align Belgium’s tax policy?”


Following the adoption of the OECD BEPS action plan in 2015 and its wider implementation worldwide (ATAD directives, corporate tax reform in Belgium), the OECD is now tackling the remaining challenges linked to the digitalising economy and the taxation of highly digitalised businesses that operate remotely (i.e. that do not have a physical presence) and generate (high) value in the user/market jurisdictions.

These challenges call for an overhaul of the international tax system for MNEs, encompassing:

  • the reallocation of taxing rights among countries, with greater focus on user/market countries;
  • the redefinition of the concept of permanent establishment, introducing a new nexus that does not depend on physical presence in the user/market jurisdiction;
  • the applicability of the arm’s-length principle and the need to go beyond this principle in order to allocate more taxing rights to the user/market jurisdictions;
  • the calculation of taxable profits on a consolidated basis, based on international accounting standards.

Discussions within the OECD are progressing rapidly. We expect a high-level proposal to be submitted to the G20 Finance Ministers at their meeting on 17 October 2019, allowing the Inclusive Framework (134 countries) to reach a global consensus by the end of January 2020. A discussion draft will be published in October and a public consultation is scheduled to take place in Paris on 21-22 November 2019.

The OECD’s activities go far beyond the taxation of digital companies alone and will affect the whole economy, so it is crucial that all businesses are aware of the changes and can anticipate their actual impact in good time.

To this end, Agoria and FEB are organising a full-day tax seminar on 13 November, where the very best international tax experts will be on hand to offer guidance and advice.

During the morning session, we will extensively analyse the OECD’s activities: the two pillars (reallocation of taxing rights and the global anti-base erosion proposal), the improvement of dispute resolution mechanisms and the various studies intended to identify the budgetary and macroeconomic impact of the proposals.

The first half of the afternoon will be devoted to further analysis of the tangible consequences. Participants will discuss three specific questions: how will these proposals impact tax incentive schemes for R&D and innovation? How will parent companies and (regional) headquarters have to adapt? How can we prepare businesses for new and increased tax compliance?

A panel discussion will take up the second half of the afternoon. This discussion will predominantly aim to draw conclusions regarding the expected changes so as to help companies clearly identify the changes and new challenges they can expect. This will also enable all participants to take part in the public consultation and better voice their concerns and suggestions. The panel discussion will also strive to get people thinking about the future of the corporate tax system in Belgium in order to assess whether it can handle the fundamental changes to the international tax system currently being discussed.

Last but not least, participants will have plenty of opportunities to ask questions, either during the sessions or during the three breaks, including the walking lunch.


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