Photo of Julie Permeke

Julie Permeke

Associate
Baker & McKenzie CVBA/SCRL

Biography

Julie Permeke is a senior associate in the Tax Practice Group of the Brussels office. She joined Baker McKenzie in 2016 after several years of experience as a tax lawyer in other well reputed Benelux law firms.

She also works as a voluntary researcher in the tax department of the Free University of Brussels (VUB).

Julie has been listed as a recommended tax lawyer in Legal 500.

Practice Focus

Julie has 10 years of extensive experience in tax controversy and tax advisory work.

She has developed significant experience in complex procedural and dispute resolution tax matters, and represents clients in every stage of a tax dispute (e.g., assistance during tax audits, negotiating settlements, filing tax complaints and representation before the tax courts). She assists clients facing complex national or multijurisdictional tax audits and also helps clients in dealing with (or preparing for) tax dawn raids (including ediscovery matters).

Julie has also extensive experience in national and international tax planning. She developed particular expertise in the field of wealth management, assisting financial intermediaries and HNWI on personal tax planning and management of estates. In this context, she has also assisted many HNWI with migrations from and to Belgium.

Representative Legal Matters

  • Defending a US multinational before the Tax Court on the legality of certain information copied by the Belgian tax authorities during a tax dawn raid and the recovery thereof.

  • Defending a US multinational before the Court of Appeal and the Constitutional Court on the possibility of levying a new tax assessment in the hands of a liquidator (after the initial tax assessment levied in the hands of the liquidated company has been annulled) and on the tax deduction of interest payments in the context of a leveraged equity distribution.

  • Defending multiple multinationals with respect to transfer pricing audits and tax audits focused on passive income streams (dividend, interest & royalty payments) in the context of beneficial ownership and alleged tax abuse.

  • Assisted several US multinationals in dawn raids carried out by the Special Tax Investigation Office.

  • Representing multiple clients in tax audits and litigation with respect to R&D incentives.

Professional Associations and Memberships

  • International Fiscal Association (IFA), Belgian branch - Director
  • Free University of Brussels (VUB) - Voluntary researcher in the tax department
  • Belgian Association for Tax Lawyers - Member
  • Ladies in Law Luxembourg Association - Member

Admissions

  • Brussels~Belgium (2011)

Education

  • Luxembourg Chamber of Commerce (Cycle B: Fiscalité des entreprises) (2020)
  • EHSAL (Post Graduate Course Corporate Finance) (2016)
  • Free University of Brussels (Post Graduate Degree Tax) (2012)
  • King's College London (LLM Tax and Competition Law) (2011)
  • Katholieke Universiteit Leuven (Master in Law) (2010)
  • Katholieke Universiteit Leuven (Bachelor in Law) (2008)

Languages

  • Dutch
  • English
  • French

Julie gives presentations and publishes articles on tax topics on a regular basis. Julie regularly contributes to domestic and international tax doctrine, e.g.: 

  • Co-author, "Belgian tax measures improving the liquidity and solvency position of corporate taxpayers in the context of COVID-19: the loss carry-back regime and the reconstitution reserve", TBF, 2020

  • Author, "Changes affecting the Belgian (holding) tax regime for dividends and capital gains: taking the bad with the good", TBF, 2018

  • Co-author, "Chapter 'Belgium' in The Transfer Pricing Law Review", 2017

  • Co-author, "General observations on and an overview of the development of a GAAR on an international level through the BEPS-initiative", in New Taxation. Studies in honor of Jacques Malherbe, 2017

Presentations 

 She also regularly speaks at tax seminars/webinars, e.g.:

  • Speaker, COVID-19: New Belgian tax measures and other (international) tax considerations, 2020

  • Speaker, DAC 6: the EU Mandatory Disclosure regime, 2020