A Critical Analysis under European, French and Belgian Law[1] Part II : The legal professional privilege in the common constitutional tradition and the requirements under Article 52 of the Charter for restricting fundamental rights. Introduction The first part found that under European, Belgian and French law the protection of Article 47 of the Charter…
A Critical Analysis under European, French and Belgian Law[1]. Part I : The incompatibility with European, French and Belgian Law of precluding the protection under Article 47 of the Charter for legal counsel given by attorneys. Introduction The opinion of the Advocate General Athanasios Rantos was highly anticipated. Indeed, it was the first time…
Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium Raphaël Devroye – Transfer Pricing Manager at PwC Belgium In a recent judgement[1], the Belgian Court of Appeal of Ghent ruled in favour of the taxpayer as regards a transfer pricing case in relation to intangibles. Even though the case is complex…
On April 5, 2021, U.S. Treasury Secretary Janet YELLEN “grabbed the attention of the occupants of corner offices worldwide with a speech to the Chicago Council on Global Affairs. The headline was a call for countries to agree on a global minimum tax rate for large companies.” (The Economist, April 8, 2021). In the slipstream,…
Lawyers across Europe holding their breath while awaiting the General Court’s ruling on the Belgian Excess Profits case were doubtlessly disappointed. On Valentine’s Day, the General Court reminded the European Commission that “tough love” is always a possibility, but the Commission’s defeat is no mortal blow. Its decision was annulled on more or less “technical”…
