CAYMAN TAX 2.1 – sharpened teeth or mere dentures? A first update based on the draft bill as finally submitted to the Belgian parliament.

The draft program law - which was submitted by the Belgian government to parliament on November 23, 2023, and has since been published on November 28, 2023, on the parliament's website - after a rather critical opinion from the Council of State, proposes a whole number of changes to the cayman tax to ensure - in its own words - that several "loopholes" are closed. Some of the new measures immediately raise additional questions as they detract from the internal logic of the cayman tax. Due to lack of time, the Council of State could neither review nor comment properly on all these provisions. It remains to be seen whether the entirety of this draft bill will pass the test of the Council of State and possibly the Constitutional Court. This draft bill makes the cayman tax even more illogical and arbitrary than before. Moreover, it is striking that the bill is very one-sidedly "in favor of the tax authorities" and does not at all meet the numerous concerns on the part of taxpayers already expressed in the doctrine on the subject.

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Tiberghien - CAYMAN TAX 2.1 – sharpened teeth or mere dentures? A first update based on the draft bill as finally submitted to parliament.