Tax | Fieldfisher
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Fieldfisher’s Belgian Tax Practice’s motto could be Charles Mingus’ quote: “Making the simple complicated is commonplace; making the complicated simple, awesomely simple, that’s creativity". Our clients praise our team for its “massive expertise” (International Tax Review 2023) to guide them through the increasingly complex tax world, in both non-contentious and contentious tax matters.

Main areas of expertise

  • Assessing reorganization opportunities;
  • Implementing the preferred restructuring opportunities;
  • Performing a tax structuring;
  • Performing a tax due diligence;
  • Setting-up management incentive plans;  
  • Drafting contracts; and
  • Negotiating.

  • Designing a transfer pricing policy;
  • Performing functional analysis;
  • Performing benchmarks;
  • Implementing a transfer pricing policy (contracts);
  • Business-model optimization; and
  • Transfer pricing audits and litigations.

  • Assisting clients during tax audits;
  • Representing clients before Belgian or European Courts (including Constitutional Court and European Court of Justice);
  • Negotiations with Conciliatory Boards; and
  • Assisting clients with dawn-raids.

  • Assessing ruling opportunity;
  • Drafting ruling requests; and
  • Meetings with Ruling Commission

  • Performing an Innovation tax incentives assessment (Innovation Income Deduction, Partial Exemption of Professional withholding taxes, R&D Tax Credit, Investment Deduction and copyrights);
  • If needed, requesting a ruling;
  • Implementing the incentives (legal and economic aspects); and
  • Assisting clients in the framework of tax audits and litigations in relation to innovation tax incentives

  • Lobbying;
  • Negotiating with governmental authorities; and
  • Drafting laws and amendments.

  • Tax amnesty;
  • Tax fraud and compliance;
  • White collar criminal law;
  • Anti money laundering.

Team Work

Our lawyers always work closely with our specialists from other departments or members from the Fieldfisher network to provide comprehensive and practical advice on a variety of complex tax issues, including cross-border restructuring, complex management incentive plans or transfer pricing studies.

Recent Deals and Highlights

  • Sell-side due diligence and restructuring of a group of 100+ entities in Belgium.
    • Drafting a windfall profit tax applicable to the energy sector.
    • Structuring and set up of a Belgian based Pan European data exchange platform (Project Gaia-X).
    • Tax and legal due diligence before the client's submission of a bid for the acquisition of a dark fibers network in Belgium. Advising on valuation and qualification of the assets from an indirect tax perspective. Assistance on the submission of the offer and closing of the deal.
    • Reorganization of transfer pricing policies and of assets, functions, and risks in various countries to realign with the new business reality. This matter involved a business model optimization, requiring important transfer pricing work including valuations and benchmarks, multiple “business restructurings”, as well as more general tax and indirect tax issues.
    • Design of the transfer pricing policy of a Belgian based technology firm which has a presence in France. This included a transfer pricing study (including benchmarks) performed with our transfer pricing specialists and a cross-border assessment (France) of the best structure possible to develop foreign activities.
    • Successful representation in a high-profile criminal tax case involving charges of corruption and tax fraud.
    • Our team was mandated by one of the largest shareholders of two listed companies (BEL20), in the framework of an administrative and judiciary contentious matter in relation to multi-million Belgian withholding taxes on dividends relating to shareholdings of less than 10% of these companies’ capital but with an investment value of more than EUR 2,5m.
    • Advisory assistance in relation with expected impact of the “Unshell” Directive (ATAD 3) on the client’s European business model, one of the most important corporate services providers worldwide.
    • Our team (in the role of main family trusted adviser) was mandated to manage complex contentious and non-contentious matters (general counsel) in the framework of high stake ongoing (civil and tax) litigations in various countries.
    • Our team acts as the special tax adviser of the key shareholder of the main holding company of one of the wealthiest European family's active notably in the retail sector.
    • Litigation assistance in relation to various multimillion foreign tax credits matters (involving several countries) which have resulted in various landmark Supreme Court decisions and various landmark case-law.