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    UAE Corporate Tax Registration – Deadline Set

    UAE Corporate Tax Registration – Introduction

    The United Arab Emirates (UAE) has established specific deadlines for the application process of Corporate Tax (CT) Registration.

    This move follows the implementation of the UAE CT law, which came into effect for the financial year starting on or after 1 June 2023.

    The Federal Tax Authority’s Decision No. 3 of 2024, effective from 1 March 2024, outlines the crucial timelines for entities to comply with this registration requirement, emphasizing the nation’s commitment to a structured tax framework.

    Key Registration Deadlines

    Resident Juridical Persons

    Entities established or recognized before March 2024 must adhere to specified deadlines based on the issuance date of their earliest license. These are set out in a table in the Decision (link provided above)

    Those incorporated or recognised post the decision’s effective date must secure their Tax Registration within three months from their date of incorporation, establishment, or recognition.

    Foreign Companies

    Entities with a Place of Effective Management (POEM) in the UAE need to obtain registration within three months from the end of their financial year.

    Non-Resident Juridical Persons

    Similar timelines apply, with specific deadlines set for non-resident entities established or recognized prior to and following March 2024.

    Natural Persons

    Individuals engaged in business or professional activities must apply for Tax Registration by stipulated deadlines to ensure compliance.

    Penalties for Non-Compliance

    Failure to submit the CT Registration application within the designated timelines incurs a substantial penalty of AED 10,000, underscoring the importance of timely action to avoid financial repercussions.

    Implications for Businesses

    This structured approach to CT Registration necessitates careful planning and evaluation, particularly for foreign companies operating in the UAE through various business models.

    The decision signifies the UAE’s proactive stance in tax regulation, aiming to streamline the process while ensuring entities contribute their fair share to the national economy.

    Entities, both resident and non-resident, must diligently assess their operations within the UAE to adhere to the new registration mandates.

    This includes evaluating any exposure related to Permanent Establishments, Nexus, and POEM, and initiating the registration process promptly to sidestep penalties.

    Conclusion – UAE Corporate Tax Registration

    The Federal Tax Authority’s recent decision marks a significant step in reinforcing the UAE’s corporate tax framework, aligning with global tax practices and enhancing the nation’s competitiveness.

    Businesses operating within the UAE’s jurisdiction must now navigate these new requirements with strategic foresight, ensuring compliance to maintain their standing and avoid penal implications.

    Final thoughts – UAE Corporate Tax Registration

    If you have any queries about this article on UAE Corporate Tax Registration, then please get in touch

    IRS Launches Initiative to Target High-Income Non-Filers

    IRS Launches  Initiative to Target High-Income Non-Filers – Introduction

    In a significant move to clamp down on tax evasion, the Internal Revenue Service (IRS) unveiled a new initiative on February 29, aimed at individuals who have neglected to file their income tax returns for 2017 and subsequent years.

    What’s it all about?

    This program, powered by the financial backing of the Inflation Reduction Act, represents a continuation of the IRS’s intensified efforts to scrutinize the tax compliance of large corporations, partnerships, and high-net-worth individuals, a strategy highlighted in a GT Alert from September 2023.

    This initiative also aligns with the IRS’s ongoing operations to recover taxes from millionaires who owe substantial amounts in back taxes.

    Thanks to these concerted efforts, the agency has successfully recuperated nearly $500 million to date.

    Who is it targeting and how?

    The current non-filer campaign specifically targets taxpayers who earned between $400,000 and $1 million from 2017 to 2021.

    The IRS plans to dispatch over 100,000 compliance letters to this demographic, sending out between 20,000 and 40,000 letters (CP-59) each week.

    Additionally, for those with incomes exceeding $1 million, over 25,000 individuals will receive compliance notifications.

    The IRS identifies potential non-filers in these income brackets using third-party data, including information from W-2s and 1099 forms, among other sources.

    IRS warning

    The IRS has issued a stern warning to these high earners, urging them to promptly rectify their filing status to avoid further notices, escalating penalties, and the possibility of criminal prosecution.

    Taxpayers who disregard the initial compliance letters will face additional notifications and could be subjected to audit and collection enforcement measures.

    In extreme cases, the IRS has the authority to prepare a Substitute for Return (SFR) for non-filers, using only reported income information.

    This action could lead to a higher tax liability for the taxpayer, as it doesn’t account for any deductions or exemptions they may be entitled to.

    Such individuals might then find themselves compelled to either settle the increased tax debt or challenge the IRS’s assessments in court.

    IRS Launches New Initiative to Target High-Income Non-Filer – Conclusion

    The message from the IRS is clear: with enhanced resources and a firm commitment, the agency is actively pursuing high-income individuals who have failed to file their tax returns.

    This initiative underscores the importance of staying compliant with tax filing obligations and consulting a trusted tax professional if you’ve missed filing returns for 2017 or later years.

    Final thoughts

    If you have any queries around this article, or US tax matters more generally, then please get in touch with us.

    Malta Faces Crucial Anti-Money Laundering Reforms to Exit FATF Grey List

    Malta AML Reforms to Exit FATF Grey List – Introduction

    Malta has been tasked with implementing three essential reforms to its anti-money laundering (AML) strategies to be removed from the Financial Action Task Force’s (FATF) enhanced monitoring list, commonly referred to as the grey list.

    Following an agreement on an action plan with the FATF, Malta’s government is under pressure to address significant issues identified by the global financial crime watchdog. 

    FATF’s Action Plan for Malta: Key Reforms

    General

    The action plan outlines a comprehensive strategy for Malta, focusing on:

    Accurate Beneficial Ownership Reporting

    Malta must ensure that company ownership information is precise, with strict enforcement actions against inaccuracies.

    This includes imposing sanctions on legal persons and gatekeepers failing to maintain accurate beneficial ownership information.

    Enhanced Use of Financial Intelligence

    The government’s Financial Intelligence Analysis Unit (FIAU) is expected to better utilize financial intelligence to support the pursuit of criminal tax evasion and associated money laundering cases.

    This entails clarifying the roles of the Revenue Commissioner and the FIAU.

    Targeted Analysis on Criminal Tax Offences

    The FIAU’s analytical efforts must focus on criminal tax offences to produce intelligence that aids Maltese law enforcement in detecting and investigating tax evasion-related money laundering activities in alignment with Malta’s risk profile.

    Background and International Context

    Malta, alongside Haiti, the Philippines, and South Sudan, was grey-listed by the FATF, signaling the need for enhanced AML measures.

    Despite having a robust legal framework on paper, Malta’s practical implementation of these laws has been under scrutiny.

    The nation’s commitment to fighting tax crimes and policing beneficial ownership rules is central to the FATF’s concerns.

    Progress and Remaining Challenges

    Although Malta has made significant strides in addressing some issues flagged in 2019, including improving financial intelligence analytics and resourcing law enforcement, the FATF’s latest review indicates that critical areas still require attention.

    The Maltese government has acknowledged progress on most recommended actions but admits that three critical points have only been partially addressed.

    Government Response and Economic Implications

    The Maltese government has expressed disagreement with the grey-listing, emphasizing its dedication to rectifying the remaining deficiencies promptly.

    The economic impact of the FATF’s decision on Malta, a notable financial hub, hinges on the government’s effectiveness in implementing the necessary reforms.

    Rating agencies and investors are closely watching the situation, as Malta’s attractiveness for foreign investment is at stake.

    Malta AML Reforms to Exit FATF Grey List – Conclusion

    Malta’s path to exiting the FATF grey list is paved with stringent AML reforms and enhanced financial transparency measures.

    The nation’s ability to fulfill the FATF’s action plan will not only determine its removal from the grey list but also reinforce its standing as a reliable and compliant financial centre.

    The Maltese government’s commitment to these reforms is crucial for restoring international confidence and securing Malta’s economic future.

    Final Thoughts

    If you have any queries regarding this article relating to Malta AML Reforms to Exit FATF Grey List, or Maltese tax matters, then please get in touch.

    IRS Targets Private Jet Usage: US Revenue aims High with New Initiative

    IRS Targets Private Jet Usage – Introduction

    The Internal Revenue Service (IRS) is setting its sights on the skies, announcing an upcoming audit initiative focused on the use of private jets by large corporations, partnerships, and high-income individuals.

    Perhaps they’ve been watching Succession?

    Surge in Personal Use of Private Jets?

    This move aims to look at the allocation of aircraft usage between business and personal purposes, a practice that has seen significant growth in recent years.

    According to a report by the Wall Street Journal, executive personal use of corporate jets has surged by 35% since 2015, with spending on such flights increasing by a staggering 92%.

    The Fright Plan

    Despite previous audits in this area, the IRS believes that private aircraft usage has not been sufficiently monitored over the past decade.

    With plans to expand the team of examiners, the IRS indicates that the number of audits concerning aircraft usage could rise based on the findings of this initial initiative.

    Key Areas of Focus

    The audits will investigate whether:

    IRS Commissioner’s Statement

    IRS Commissioner Werfel emphasised the agency’s commitment to increasing scrutiny on high-income taxpayers, signaling a broader effort to ensure compliance among the wealthiest individuals and organisations.

    This initiative aligns with the objectives set forth by the Inflation Reduction Act, aiming to reverse historically low audit rates and enhance the focus on substantial income and corporate entities.

    Challenges and Recommendations

    Tax law surrounding the business use of aircraft is complex, and maintaining accurate records can be challenging for taxpayers.

    Issues often arise due to inadequate contemporaneous documentation, leading the IRS to classify the aircraft as an “entertainment facility” under IRC Section 274 in some examinations.

    This classification can result in the denial of all deductions, including those associated with business use.

    As such, affected taxpayers that are utilising private jets are advised to review and assess whether their record-keeping practices are fit for purposes. In other words, they can ensure a clear distinction between business and personal use to comply with IRS requirements.

    IRS Targets Private Jet Usage – Conclusion

    The IRS’s new audit initiative on private jet usage underscores the agency’s dedication to ensuring tax compliance among high-income individuals and large entities.

    As the IRS bolsters its examination efforts, taxpayers should take proactive steps to ensure their usage of business aircraft aligns with tax laws and regulations, particularly in maintaining and documenting usage accurately.

    Final thoughts

    If you have any queries about this article, IRS Targets Private Jet Usage, then please get in touch.

    Texas Man Faces Historic Charges Over Crypto Capital Gains Tax

    US Historic Crypto Tax charges – Introduction

    In a groundbreaking case that signals the Internal Revenue Service’s (IRS) increasing scrutiny of digital assets, a Texas man has been indicted for filing false tax returns related to unreported cryptocurrency transactions.

    This marks a significant moment in the enforcement of tax laws on digital currency gains, underscoring the federal government’s commitment to upholding tax compliance in the cryptocurrency space.

    Background

    The Department of Justice (DoJ) announced that an Austin resident was charged with filing false tax returns from 2017 to 2019, during which he allegedly failed to report the sale of approximately $3.7 million worth of Bitcoin.

    These unreported sales resulted in substantial capital gains, part of which was used to purchase a residence.

    The indictment also accuses the individual of structuring cash deposits to evade currency transaction reporting requirements, further complicating the case.

    A Historic Prosecution

    This prosecution is notable not just for its focus on cryptocurrency but because it represents what is believed to be the first-ever criminal case concerning the tax implications of legal source crypto transactions in the United States.

    Implications of the Case

    The charges underscore the IRS’s stance: the vast majority of digital asset transactions are taxable and must be reported.

    With the IRS placing the crypto question prominently on tax forms, the message is clear—ignorance or avoidance of reporting digital assets is fraught with legal peril.

    This case serves as a stark reminder of the consequences of failing to comply with tax obligations related to cryptocurrency gains.

    The Importance of Reporting and Compliance

    As digital currencies continue to integrate into the mainstream financial ecosystem, the IRS and the DoJ are signaling their intent to rigorously enforce tax laws in this domain.

    For cryptocurrency investors and users, this case underscores the importance of maintaining meticulous records and ensuring all taxable transactions are accurately reported.

    Presumption of Innocence

    It’s crucial to remember that an indictment is merely an allegation, and the defendant in this case is presumed innocent until proven guilty in a court of law.

    However, if convicted, the charges carry substantial penalties, including potential prison time for each count of structuring and filing false tax returns.

    US Historic Crypto Tax charges – Conclusion

    This landmark case is a wake-up call to all who engage in cryptocurrency transactions to take their tax reporting obligations seriously.

    With the IRS and federal prosecutors now actively pursuing legal actions against tax evasion in the crypto space, ensuring compliance has never been more critical.

    Further, one suggests the rest of the world is likely to follow suit.

    Final thoughts

    If you have any thoughts on this article regarding US Historic Crypto Tax charges, or any US tax matters, then please get in touch.

    US: Washington Finalises Beneficial Ownership Database Access

    US Beneficial Ownership Access – Introduction

    In a key development for corporate transparency, the Financial Crimes Enforcement Network (FinCEN) of the US government has initiated the process of receiving beneficial ownership information reports as mandated by the Corporate Transparency Act 2021.

    This strategic move aims to fortify the battle against financial crimes by ensuring clarity in company ownership structures.

    Submission Requirements and Deadlines

    Under the new framework, existing companies are provided with a one-year window to submit their reports, while newly established entities must adhere to a 90-day filing deadline post-creation or registration with FinCEN.

    The agency is entrusted with the administration and secure management of the beneficial ownership database.

    Reporting entities are required to furnish comprehensive details for each beneficial owner, including their name, date of birth, address, and a valid identification number from an approved list of documents such as a US driving license, passport, or other state or local government-issued documents, including foreign passports.

    FinCEN’s Final Rule and Access Rights

    As 2023 drew to a close, FinCEN unveiled a final rule elucidating the conditions and authorized entities eligible to access the national beneficial ownership database.

    This rule, largely based on the previous year’s draft but incorporating notable amendments, is set to progressively allow access from 20 February onwards.

    The list of entities with granted access includes federal, state, and foreign law enforcement agencies, financial institutions, regulators involved in customer due diligence processes, and the US Treasury.

    Expansion of ‘Customer Due Diligence Requirements’

    A significant enhancement in the final rule is the broadening of the ‘customer due diligence requirements’ clause.

    This expansion now covers legal obligations designed to counteract money laundering, terrorism financing, or protect the US’s national security.

    Consequently, financial institutions are empowered to integrate FinCEN’s beneficial information into their due diligence and suspicious activity monitoring and reporting mechanisms, thereby reinforcing their compliance with the Banking Secrecy Act or sanctions enforced by the US Treasury’s Office of Foreign Assets Control.

    Phased Implementation and Pilot Program

    The implementation of access to the beneficial ownership information will commence on 20 February with a pilot program aimed at key federal agency users.

    This initial phase will be followed by extending access to other federal agencies, and subsequently to state and local law enforcement agencies.

    The final rule also paves the way for financial institutions to share beneficial ownership information with employees or contract personnel outside the USA, with specific exceptions, thus addressing operational challenges for institutions with extensive international operations and compliance functions.

    Database Operation and Data Access

    While the precise operational framework of the database remains under wraps, FinCEN has clarified its stance against providing bulk data exports to authorized users.

    Instead, an application programming interface is expected to be made available, allowing these users to conduct specific queries in the database.

    US Beneficial Ownership Access – Conclusion

    This landmark regulation marks a significant stride in the US government’s ongoing efforts to enhance corporate transparency and combat financial crimes effectively.

    If you have any queries about this article on US Beneficial Ownership Access, or any other US matters, then please get in touch.

    BVI and Online Submission for FATCA, CRS and CbC Reports

    BVI and Online Submission for FATCA, CRS and CbC Reports – Introduction

    The BVI has made a significant stride towards enhancing transparency and tax information exchange.

    It has mandated that, from 24 January 2024, all entities under its jurisdiction with certain financial reporting responsibilities, are to submit their reports exclusively through the BVI Financial Accounting Reporting System (BVIFARS).

    The relevant reporting responsibilities include:

    Background and Impetus for Change

    The shift to the digital platform is in response to the recommendations from the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum).

    Despite BVI’s AEOI legislation aligning with the Global Forum’s technical standards for years, the OECD’s 2022 review identified significant gaps in the actual AEOI implementation.

    The spotlight was on the “significant issues” concerning the assurance that Reporting Financial Institutions were accurately carrying out due diligence and reporting procedures.

    The Global Forum hence called for the BVI to fortify its domestic compliance framework to solidify CRS implementation effectiveness.

    Challenges and Proactive Measures by the BVI Government

    The BVI government candidly attributed the shortcomings to the devastating impact of Hurricanes Irma and Maria and the subsequent global COVID-19 pandemic, which significantly hindered their information exchange capabilities.

    In light of these challenges, the government requested a supplementary review to validate the improvements in their AEOI processes.

    This request was approved, with an on-site visit by the OECD slated for the first quarter of 2024 to confirm the BVI’s adherence to the stipulated conditions.

    Operational Details of the BVIFARS Portal

    With the activation of BVIFARS in January 2024, entities are now transitioning to this centralized online system for their FATCA, CRS, and CbC report submissions.

    A notable feature of this new system is the imposition of an annual usage fee of USD185 for each reporting entity, payable by 1 June each year.

    Key Deadlines and Compliance Requirements

    Entities are required to be vigilant about the following critical deadlines:

    Additionally, each legal entity is obligated to furnish its registered agent with the mandated economic substance information annually.

    The registered agent, in turn, must relay this data to the BVI International Tax Authority within six months from the end of the pertinent reporting period.

    BVI and Online Submission for FATCA, CRS and CbC Reports – Conclusion

    This transformation in the reporting process for BVI entities signifies a proactive approach to addressing the challenges previously flagged by the OECD.

    By embracing a digital and centralized reporting system, the BVI is taking definitive steps towards bolstering its compliance framework, thereby reinforcing its commitment to international tax transparency and cooperation.

    If you have any queries on this article about BVI and Online Submission for FATCA, CRS and CbC Reports, or BVI matters in general, then please get in touch.

    Citizenship and Residency by Investment Programs: Striking a balance?

    Citizenship and Residency by Investment – Introduction

    In the landscape of global investment, Citizenship by Investment (CBI) and Residency by Investment (RBI) programs offer a compelling gateway for foreign investors seeking expedited citizenship or residency in other countries.

    These initiatives, while promising economic growth through substantial foreign investment, have a flip side.

    It is alleged that they’ve become a magnet for unscrupulous individuals—criminals and corrupt officials—who exploit these programs to evade justice and launder billions of dollars obtained through illicit activities.

    Who yer gonna call?

    The FATF team, of course.

    Recently, the Financial Action Task Force (FATF) teamed up with the Organisation for Economic Co-operation and Development (OECD) to delve into the risks and vulnerabilities of these programs in their joint project.

    Their findings underscored the inherent dangers associated with CBI/RBI programs, particularly in terms of money laundering, fraud, and their adverse effects on public integrity, taxation, and migration.

    FATF President T. Raja Kumar highlighted the dual nature of these investment schemes, acknowledging their potential for stimulating economic growth while underscoring the grave threats they pose when abused by criminals and corrupt entities.

    “Golden” passports and visas extended through these programs often fall prey to exploitation by individuals looking to obfuscate their identities, launder illicit gains, or perpetrate further criminal activities.

    The report

    The report illuminates how these programs offer criminals enhanced global mobility, enabling them to cloak their identities and illegal undertakings behind opaque corporate structures in foreign jurisdictions.

    Complex and multifaceted, these international investment migration programs frequently involve multiple government agencies, intermediaries, and lack proper governance, making them vulnerable to abuse by professional facilitators.

    OECD Secretary-General Cormann emphasized the alarming scale of exploitation within these citizenship and residency programs, characterizing it as a multi-billion-dollar enterprise utilized by criminals to launder the proceeds of fraud and corruption, evade accountability, or access third-party countries.

    Countering the threats

    To counter these threats, the report proposes a series of measures and best practices aimed at mitigating risks.

    It advocates for robust due diligence mechanisms, transparency, and integrity frameworks to be integrated into the fabric of these investment migration programs.

    Additionally, it stresses the importance of dissecting how criminals exploit these programs and delineates the need for clear demarcation of roles and responsibilities among involved parties to spot and prevent fraudulent activities.

    Citizenship and Residency by Investment Conclusion

    In essence, while CBI/RBI programs offer a potential gateway to economic growth, their unchecked exploitation poses a severe threat to global financial systems and integrity.

    The onus lies on policymakers and administrators of these programs to adopt stringent measures, ensuring these schemes aren’t hijacked for nefarious purposes.

    The report serves as a clarion call to establish a delicate equilibrium between economic prosperity and robust security measures within the realm of investment migration programs.

     

    If you have any queries about Citizenship and Residency by Investment programs, then please get in touch.

    The Economic Crime and Corporate Transparency Act 2023

    The Economic Crime and Corporate Transparency Act 2023 – Introduction

    Following a bumpy legislative journey, the Economic Crime and Corporate Transparency Act 2023, formerly the Economic Crime and Corporate Transparency Bill, received Royal Assent on 26 October 26 2023.

    Hurray!

    Or should we pause with such unusual exuberance?

    What is it?

    This new Act encompasses extensive reforms, notably affecting the limited partnership regime and corporate criminal liability.

    This article will highlight some of those amendments that relate to company administration regime under the Companies Act 2006 (CA 2006).

    Key Reforms Overview

    The Act introduces comprehensive changes to the company incorporation and administration processes, aiming to enhance corporate transparency and combat the misuse of the UK companies regime in facilitating economic crimes.

    The key measures include:

    Empowered Registrar Role

    The Act will empower the Registrar of Companies, significantly augmenting their authority to scrutinize and reject filed information at Companies House.

    This transformative shift makes Companies House more proactive, ensuring the accuracy and reliability of company-related data.

    Moreover, the Registrar may demand additional information for filings.

    Identity Verification

    The Act mandates the verification of identities for all current and proposed directors, as well as persons with significant control (PSCs).

    Acting as a director without verified identity will be an offense, potentially leading to disqualification.

    Furthermore, those filing documents on behalf of a company must also undergo identity verification.

    Filing Regime Changes

    Solely officers, employees, or authorized corporate service providers, with verified identities, can file documents at Companies House, restricting unauthorized filings.

    Company Administration Amendments

    Companies must maintain a registered office and a registered email address at an “appropriate” location to receive correspondence from the Registrar.

    Enhanced confirmations will be required during incorporation and in annual confirmation statements.

    Statutory Registers and Members

    Most statutory registers (except the register of members) will be abolished, with Companies House now tasked to maintain such records.

    The register of members must comply with specified information requirements, increasing the onus on companies to promptly notify changes to directors and PSCs.

    Timeline and Implementation

    Many measures necessitate secondary legislation, expected to roll out over the next 12-24 months. Companies House requires operational reforms to meet its elevated responsibilities, including new systems for identity verification.

    Certain obligations have a six-month transitional period post-enforcement.

    Some measures, not dependent on secondary legislation, are expected to come into force in early 2024.

    Implications and Preparation

    Companies need to update their internal processes to align with the new regime.

    Company secretaries and individuals filing for companies must await finalized regulations on the verification process.

    Directors and PSCs/RLEs must be informed and prepared for the identity verification requirements.

    Company Secretaries – to do list

    1. Verification Process Preparation: Understand the verification process once finalized. Prepare directors and individuals filing for companies for the upcoming verification requirements.
    2. Group Structure Familiarization: Larger organizations involved in periodic group reorganizations or incorporating subsidiaries should acquaint themselves with the new incorporation regime.
    3. Registrar’s Query Powers: Proactively review internal records against Companies House data to rectify any inconsistencies that may lead to information rejection.
    4. Registered Office Compliance: Ensure compliance with the Act’s criteria for a company’s registered office and maintain a monitored registered email address.
    5. Transition from Statutory Registers: Assess the need for internal record maintenance post the abolition of certain statutory registers.
    6. Register of Members Compliance: Understand the register of members’ changes and ensure accurate and updated member information.

    The Economic Crime and Corporate Transparency Act 2023 – Conclusion

    The Economic Crime and Corporate Transparency Act 2023 introduces substantial changes, requiring companies to adapt and prepare for an evolved compliance landscape.

    Make sure you are up to speed.

    If you have any queries regarding the The Economic Crime and Corporate Transparency Act 2023 then please get in touch.

    ULD Quater: Regularising the irregular

    ULD Quater – Introduction

    The end is nigh for Belgium’s so-called Unique Liberation Declaration quater (ULD quater) procedure.

    This has allowed Belgian residents to regularise their tax position.

    It will come to an end with effect from 31 December 2023.

    ULD Quater – Present Status

    ULD Quater has been a lifeline for taxpayers looking to voluntarily regularise their previously undeclared assets.

    In exchange for a flat-rate tax of 40% on assets with uncertain origins, taxpayers could find relief from criminal prosecution, particularly for money laundering offenses.

    The certificate of regularisation issued upon completion of the process has been invaluable, especially for Belgian banks, allowing them to accept assets with less than perfectly traceable origins.

    This has been a boon, even for taxpayers beyond reproach but unable to provide written proof of their asset’s origin, often due to the antiquity of the assets in question.

    ULD Quater: The Final Chapter

    A crucial update came in July 2023 when the tax authorities clarified that provisional “pro forma” and “materially incomplete” declarations for 2023 wouldn’t be accepted with the intent of completing them in 2024.

    However, reasonably complete declarations submitted in 2023 and later updated with minor additions in 2024 should still be considered admissible.

    But, the FAQs remain ominously silent about what happens after December 31, 2023.

    Beyond December 31, 2023: What’s on the Horizon?

    The looming deadline raises questions about the future of taxpayers who fail to regularise their assets by the cutoff date.

    The Belgian Minister of Finance hinted at a new procedure, suggesting that from 2024, taxpayers seeking to regularise tax-barred assets would have to declare this to the Prosecutor’s office, which would initiate an extended transaction procedure.

    However, significant uncertainties persist.

    Will the tax authorities cease processing regularizations in 2024 and redirect taxpayers to the Prosecutor’s office?

    The Prosecutor’s discretionary power over whether to prosecute or propose a transaction adds an extra layer of complexity.

    Moreover, discussions are underway to introduce a new “permanent administrative approach” to tax regularisation, which could tax up to 45% of spontaneously regularized tax-barred assets, seemingly in exchange for immunity from criminal prosecution.

    The clarity and security of this solution remain questionable.

    For those with time-barred capital, there’s the option to revive the spontaneous declaration of income to the Inspection Spéciale des Impôts / Bijzondere Belastinginspectie service, although this raises concerns about criminal immunity and the ability to regularize time-barred capital.

    Conclusion

    There is impending uncertainty beyond 2023, and with the government’s “new approach” appearing to be less favorable than ULD quater.

    As such, time is of the essence for those wishing to regularize their assets, especially in the case of repatriation.

    The clock is ticking, and the future of tax regularisation in Belgium is shrouded in uncertainty.

    If you have any queries about ULD Quater, Belgium tax or tax matters in general then please get in touch.