Michiel Stuyts

🔥𝗜𝘁’𝘀 𝗧𝗶𝗺𝗲 𝘁𝗼 #𝗦𝗰𝗿𝗮𝗽𝗣𝗶𝗹𝗹𝗮𝗿𝟮 — 𝗘𝗨 𝗖𝗼𝗺𝗽𝗲𝘁𝗶𝘁𝗶𝘃𝗲𝗻𝗲𝘀𝘀 𝗮𝘁 𝗦𝘁𝗮𝗸𝗲 📌 𝗧𝗵𝗲 𝗘𝗨’𝘀 𝘂𝗻𝗶𝗹𝗮𝘁𝗲𝗿𝗮𝗹 𝗶𝗺𝗽𝗹𝗲𝗺𝗲𝗻𝘁𝗮𝘁𝗶𝗼𝗻 𝗼𝗳 𝗣𝗶𝗹𝗹𝗮𝗿 𝗧𝘄𝗼 𝗶𝘀 𝗰𝗼𝗹𝗹𝗮𝗽𝘀𝗶𝗻𝗴 𝘂𝗻𝗱𝗲𝗿 𝗶𝘁𝘀 𝗼𝘄𝗻 𝘄𝗲𝗶𝗴𝗵𝘁. Let's focus on three critical developments that call the entire framework into question: 🇧🇪 1. 𝗕𝗲𝗹𝗴𝗶𝗮𝗻 𝗖𝗼𝗻𝘀𝘁𝗶𝘁𝘂𝘁𝗶𝗼𝗻𝗮𝗹 𝗖𝗼𝘂𝗿𝘁 𝗘𝘀𝗰𝗮𝗹𝗮𝘁𝗲𝘀 𝘁𝗼 𝘁𝗵𝗲 𝗖𝗝𝗘𝗨 On 𝟭𝟳 𝗝𝘂𝗹𝘆 𝟮𝟬𝟮𝟱, Belgium’s Constitutional Court 𝗿𝗲𝗳𝗲𝗿𝗿𝗲𝗱 𝘁𝗵𝗲 𝗨𝗧𝗣𝗥 (𝗨𝗻𝗱𝗲𝗿𝘁𝗮𝘅𝗲𝗱 𝗣𝗿𝗼𝗳𝗶𝘁𝘀 𝗥𝘂𝗹𝗲) 𝘁𝗼 𝘁𝗵𝗲 𝗖𝗼𝘂𝗿𝘁 𝗼𝗳 𝗝𝘂𝘀𝘁𝗶𝗰𝗲 𝗼𝗳 𝘁𝗵𝗲 𝗘𝗨, asking whether it violates:  • The 𝗖𝗵𝗮𝗿𝘁𝗲𝗿 𝗼𝗳 𝗙𝘂𝗻𝗱𝗮𝗺𝗲𝗻𝘁𝗮𝗹 𝗥𝗶𝗴𝗵𝘁s (Articles 15–17, 20–21),  • The 𝗧𝗙𝗘𝗨 (Articles 49 & 56),  • The principles of l𝗲𝗴𝗮𝗹 𝗰𝗲𝗿𝘁𝗮𝗶𝗻𝘁𝘆 𝗮𝗻𝗱 𝗳𝗶𝘀𝗰𝗮𝗹 𝘁𝗲𝗿𝗿𝗶𝘁𝗼𝗿𝗶𝗮𝗹𝗶𝘁𝘆. 📎 This marks the 𝗳𝗶𝗿𝘀𝘁 𝗹𝗲𝗴𝗮𝗹 𝗰𝗵𝗮𝗹𝗹𝗲𝗻𝗴𝗲 to the EU’s Pillar 2 Directive and shows how Belgium—though a small country—continues to lead major tax law battles (see DAC6, potential ATAD litigation). 🧨 If UTPR is struck down, the EU's implementation model may unravel entirely. 🇩🇪 2. 𝗚𝗲𝗿𝗺𝗮𝗻𝘆 𝗦𝗲𝗻𝗱𝘀 𝗠𝗶𝘅𝗲𝗱 𝗦𝗶𝗴𝗻𝗮𝗹𝘀 In a surprising move, 𝗖𝗵𝗮𝗻𝗰𝗲𝗹𝗹𝗼𝗿 𝗙𝗿𝗶𝗲𝗱𝗿𝗶𝗰𝗵 𝗠𝗲𝗿𝘇 recently called for a 𝗽𝗮𝘂𝘀𝗲 in the EU’s Pillar 2 rollout, citing the US carve-out and resulting competitive asymmetry. 📢 Just one day later, 𝗙𝗶𝗻𝗮𝗻𝗰𝗲 𝗠𝗶𝗻𝗶𝘀𝘁𝗲𝗿 𝗟𝗮𝗿𝘀 𝗞𝗹𝗶𝗻𝗴𝗯𝗲𝗶𝗹 contradicted him, reaffirming Germany’s commitment. ⚠️ This inconsistency reveals the growing political 𝗱𝗶𝘀𝗰𝗼𝗺𝗳𝗼𝗿𝘁 across Europe. Pillar 2 was meant to be universal. It no longer is. 🌍 𝟯. 𝗢𝗘𝗖𝗗 𝗥𝗲𝗹𝗲𝗮𝘀𝗲𝘀 𝗡𝗲𝘄 𝗣𝗿𝗮𝗰𝘁𝗶𝗰𝗮𝗹 𝗘𝘅𝗮𝗺𝗽𝗹𝗲𝘀 (𝟵 𝗠𝗮𝘆 𝟮𝟬𝟮𝟱) To support implementation, the OECD published dozens of examples showing how the complex GloBE rules apply: ✔️ IIR hierarchy (top-down vs intermediate entities) ✔️ POPE (Partially Owned Parent Entity) cases ✔️ Top-up tax calculation and allocation ✔️ Double taxation mitigation under UTPR ✔️ Coordination with domestic Qualified Rules (QDMTT) 📉 The message is clear: the 𝗮𝗱𝗺𝗶𝗻𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝘃𝗲 𝗯𝘂𝗿𝗱𝗲𝗻 𝗶𝘀 𝗶𝗺𝗺𝗲𝗻𝘀𝗲. These are not policy refinements—they are red flags. 📣 𝗧𝗶𝗺𝗲 𝘁𝗼 𝗦𝗮𝘆 𝗜𝘁 𝗖𝗹𝗲𝗮𝗿𝗹𝘆: #𝗦𝗰𝗿𝗮𝗽𝗣𝗶𝗹𝗹𝗮𝗿𝟮 ✅ It’s not global. ✅ It’s too complex. ✅ It weakens the EU’s competitive position—alone. 🚨 𝗪𝗵𝗮𝘁 𝗬𝗼𝘂 𝗖𝗮𝗻 𝗗𝗼 📌 Engage with 𝗽𝗼𝗹𝗶𝗰𝘆𝗺𝗮𝗸𝗲𝗿𝘀 𝗮𝗻𝗱 (𝘁𝗮𝘅 𝗽𝗼𝗹𝗶𝗰𝘆) 𝗶𝗻𝗳𝗹𝘂𝗲𝗻𝗰𝗲𝗿𝘀 📌 Comment, repost, and 𝘂𝘀𝗲 𝘁𝗵𝗲 𝗵𝗮𝘀𝗵𝘁𝗮𝗴 #𝗦𝗰𝗿𝗮𝗽𝗣𝗶𝗹𝗹𝗮𝗿𝟮 📌 Support a smarter EU tax policy—one that balances coordination and competitiveness (I will discuss the new EU tax on MNEs separately...).  #ScrapPillar2 ✊

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We are proud to share that PXR has acted as legal advisor to Makersite on its recent 60 million Euro Series B financing round. The round was led by Lightrock and Partech, with participation of SE Ventures, Hitachi Ventures, Translink Capital, Planet A and KOMPAS VC. Makersite provides an AI-powered platform for sustainable product design and supply chain management. The technology enables manufacturers to model, analyze and optimize complex products in real time across their entire life cycle. The platform is already used by global leaders such as Microsoft, Schneider Electric and Daikin. With this new funding, Makersite will further enhance its technology, deepen integrations with key partners and scale internationally to meet accelerating global demand. Congratulations to Neil D'Souza and the entire team at Makersite. We appreciate the trust placed in us for this important transaction. PXR

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📚 The legal world is evolving fast – and leading corporate law firm Fidal is setting precedent. With Sopra Steria Next, they have built a powerful AI assistant designed with lawyers, for lawyers. Here’s how they’re transforming legal practice with tech :   ✅ 100 000+ legal documents integrated – anonymised and verified ✅ 1 250 professionals empowered, from juniors to partners   👏 With thanks to Jean-Godefroy Desmazières, Stéphane Mariotto, Aurélie KLEIN, Harold Forestier, and Maud Roux for your trust and partnership on this project.   🔎 Click to explore how Fidal IA is reshaping the legal profession: https://lnkd.in/ebeSFRaB   #LegalTech #AIforLaw #DigitalTransformation

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Press Release: Interparking and Saba become one: the strategic alliance is now effective 🤝 After reaching an agreement on 16 October 2024 and obtaining antitrust clearance, Interparking, AG Insurance (through us), APG Asset Management and CriteriaCaixa are pleased to announce the finalization of the integration of Saba by Interparking, effective as of this 1st October. Serge Fautré: "This is the start of an exciting new chapter for Interparking, which is now on track to become a leading car park operator and owner in Europe, with a mission to provide excellent parking facilities while collaborating with numerous public authorities across the continent." Read the full press release here: https://lnkd.in/exPUu9pf

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We are pleased to announce that Arnaud Nuyts and Louis Hollanders have contributed the Belgium chapter to the recently released 16th edition of Lexology In-Depth – Arbitration (2025). This annual guide provides an in-depth analysis of key arbitration jurisdictions worldwide. The Belgium chapter offers readers a comprehensive overview of recent developments in international arbitration, set against the backdrop of Belgium’s arbitration legal framework, and highlights the most significant legal and procedural developments from the past year. Access the full chapter here: https://lnkd.in/dyeanami #InternationalArbitration #Lexology #DisputeResolution #Belgium

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