This is more relevant to taxation than any other field. A tax administration dispute can have a huge impact on your business activity so you must keep your finger on the pulse in tax cases.
International taxation
Examples of international taxation
International taxation covers the tax rules applicable when individuals, companies, income, or assets have a cross-border character. It determines which country has taxing rights and how double taxation is avoided. Examples include:
- Double tax treaties
- International employment
- Salary split arrangements
- Permanent establishments
- Mutual agreement procedures
Our approach:
Today’s world is more interconnected and international than ever, with borders blurred by globalization. This dynamic environment offers countless opportunities for collaboration and growth but also brings complex regulatory and tax challenges. We assist you and your business in navigating these complexities, ensuring that your international tax matters are handled correctly and efficiently.
Our expertise in this field:
We also guide and defend individuals facing cross-border tax situations, such as salary splits, cross-border workers, and tax residency issues. We analyze your tax position, optimize your tax outcomes, and ensure compliance with all relevant laws and regulations. Whether it concerns cross-border transactions, permanent establishments, or tax treaties, we are ready to support you and defend your interests.
In practice? Illustrative cases:
CASE
A butler travels across Europe with his employer. His income was fully taxed in Belgium, even though he spent most of the year physically outside Belgium. To avoid double taxation, we filed an objection on his behalf. We guided the taxpayer in gathering the necessary factual evidence, which resulted in a favorable decision, exempting the income earned abroad from Belgian taxation in accordance with the applicable double tax treaties.
CASE
An employee of a Dutch company, working from Belgium, requested relief from double taxation in the Netherlands to avoid being taxed twice on two years’ income. He was required to pay taxes in Belgium but had already paid taxes on the same income in the Netherlands. Following a mutual agreement procedure between Belgium and the Netherlands, the Netherlands approved the request and refunded the full amount of the incorrectly withheld tax.
CASE
A retired director-majority shareholder from the Netherlands, residing in Belgium, had cashed out his self-managed pension in the Netherlands and requested exemption of the pension capital in Belgium. This was crucial to prevent the capital from being subject to the Dutch tax credit and taxed at Belgian progressive rates. The Court of First Instance ruled in his favor, but the tax authorities decided to appeal to the Court of Appeal.
Schedule a meeting?
Are you facing a similar issue or do you have questions following this case? We’d be glad to assist you – don’t hesitate to get in touch with team TAX: TeamTax@Tuerlinckx.eu
“Tax is everywhere”
“Better safe than sorry”.
This is more relevant to taxation than any other field. A tax administration dispute can have a huge impact on your business activity so you must keep your finger on the pulse in tax cases.
At Tuerlinckx Tax Lawyers, we offer specialised tax advice so that you can sleep soundly as an entrepreneur. We optimise your tax position and minimise associated risks, allowing you to focus on your core business.
Advice
Disputes
Are you looking for tax advice based on a firm foundation, written in regular language and which offers a viable solution? Then you have come to the right place at Tuerlinckx Tax Lawyers! We supplement classic tax advice with a tax risk analysis to ensure that a structure passes the tax administration or court review. Together, we go for well-founded solutions that meet both short and long-term objectives.
Count on the CORPORATE team for assistance with tax audits and discussions with the tax administration, both at the administrative stage and in court. We ascertain precisely what the tax administration will and will not allow in the specific tax files. We also explore the viability of the tax authority’s claims and the arguments you could use to make a difference in court.
Regularisations
Rulings
What if some components of your assets have not been subjected to the correct tax regime? You can still realise a rectification within a legally prescribed framework, through tax regularisation. The experts at Tuerlinckx Tax Lawyers can analyse how to use this tax technique correctly and guide you through the rest of a case.
Naturally, you want maximum certainty about the tax implications of the activities you undertake. With a tax ruling, you make clear and binding agreements with the tax authorities in advance. That legal certainty provides additional peace of mind and comfort in tax discussions. At Tuerlinckx Tax Lawyers, we have the required expertise and experience to properly guide you and your advisers through this complex process.
Advice
Are you looking for tax advice based on a firm foundation, written in regular language and which offers a viable solution? Then you have come to the right place at Tuerlinckx Tax Lawyers! We supplement classic tax advice with a tax risk analysis to ensure that a structure passes the tax administration or court review. Together, we go for well-founded solutions that meet both short and long-term objectives.
Disputes
Count on the CORPORATE team for assistance with tax audits and discussions with the tax administration, both at the administrative stage and in court. We ascertain precisely what the tax administration will and will not allow in the specific tax files. We also explore the viability of the tax authority’s claims and the arguments you could use to make a difference in court.
Regularisations
What if some components of your assets have not been subjected to the correct tax regime? You can still realise a rectification within a legally prescribed framework, through tax regularisation. The experts at Tuerlinckx Tax Lawyers can analyse how to use this tax technique correctly and guide you through the rest of a case.
Negotiations
Tuerlinckx Tax Lawyers are experienced negotiators. Our priority is always the best possible deal for our clients. Whether it concerns contract negotiations, settlements or business transactions, we provide the lasting and most beneficial solution!
