The Belgian parliament is considering a draft bill submitted on 3 October 2022 that contains various tax measures, including amendments to the statutes of limitations for investigations and assessments. As amended, this includes:
- A standard 3-year statute of limitations where a return/declaration has been timely filed
- A 4-year statute of limitations where a return/declaration is filed late or not filed;
- A 6-year statute of limitations in specific cases that require more in-depth control
- A 10-year statute of limitations in relation to complex declarations involving particular legal arrangements, hybrid mismatches, and the CFC provisions, which expands upon the existing 10-year statute of limitations where a taxpayer uses a legal arrangement in a low or no-tax jurisdiction, as well as in cases of tax evasion and fraud (extended from 7 years).
Source Orbitax
