Preface
- The document is an annual corporate tax bulletin focusing on tax trends and developments for multinational enterprises (MNEs) in 2025.
- It includes updates on pending tax legislation and other tax developments at the EU and international levels, as well as in Belgium, the Netherlands, Luxembourg, and Switzerland.
The Future Landscape
- The EU’s tax agenda has faced challenges due to political changes and a more fragmented European Parliament.
- Key issues include balancing the EU’s ambitious tax agenda with the unanimity requirement in the Council of the EU, and the impact of Donald Trump’s re-election on OECD projects.
- Major upcoming discussions include the EU’s long-term budget and new own resources for the EU.
EU and International Developments
- Pillar Two Directive: Ongoing implementation by several Member States, with legal challenges in Belgium.
- FASTER Proposal: Aims to streamline withholding tax relief procedures.
- VAT in the Digital Age (ViDA) Package: Updates VAT rules for digital reporting and single VAT registration.
- DAC9 Proposal: Facilitates filing and exchanging Pillar Two-related information in the EU.
- Other Proposals: Includes harmonizing transfer pricing principles, tackling shell companies (Unshell proposal), new EU own resources, BEFIT, HOT, and revising the Energy Taxation Directive.
EU Tax Litigation
- Increasing impact of EU acts on taxpayers, with potential for legal challenges against national measures transposing EU directives.
Belgium
- Pillar Two: Implementation of IIR and QDMTT, with compliance deadlines approaching.
- Public CbC Reporting: New requirements for MNEs with Belgian presence.
- Transfer Pricing Documentation: Updated requirements for Master File and Local File.
- VAT Compliance: Stricter rules for VAT returns and refunds, mandatory e-invoicing from 2026.
The Netherlands
- Tax Plans 2025: Various proposals including changes to earnings stripping rules, interest deduction limitations, and transaction cost deductibility.
- Pillar Two: Implementation of domestic legislation with upcoming challenges.
- Public CbC Reporting: New obligations for MNEs.
- Entity Classification Rules: Aligning Dutch rules with international standards.
- Dividend Withholding Tax: Infringement procedure by the European Commission.
Luxembourg
- Corporate Income Tax Rate: Expected reduction from 17% to 16%.
- Participation Exemption: Option to waive benefits under specific circumstances.
- Minimum Net Wealth Tax: Simplified structure based on balance sheet total.
- Pillar Two: Ongoing implementation with further legislative amendments expected.
Switzerland
- Pillar Two: Introduction of QDMTT and planned IIR implementation.
- Transfer Pricing: New guidelines and increased audit frequency.
- Beneficial Ownership: Landmark case on cross-currency swaps.
- Securities Transfer Stamp Tax: Clarifications on intermediation and exemptions.
Tax and Sustainability
- Integration of tax governance into ESG strategies is becoming increasingly important.
- New reporting obligations under CSRD and Public CbC Reporting will increase transparency and accountability.
International Tax Developments
- Ongoing work on OECD’s Pillar One and Pillar Two solutions, with uncertainties around US ratification.
- UN Framework Convention for International Tax Cooperation aims to strengthen global tax cooperation.
