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How we can help

How we can help

How we can help

Our multidisciplinary approach can help you manage your company’s transfer pricing issues by providing advice on planning, compliance and documentation, compliance dispute resolution as well as the practical implementation of your transfer pricing policy in Belgium and internationally.  

We also have significant experience in responding to and tackling the issues raised by tax authorities during audits. Our strategies are directed to be commercially viable and balanced, generating tax efficiencies and mitigating the risk of tax authority challenge. In short, our multidisciplinary team is ready to help you your transfer pricing issues through such services as:

Planning and design

Our goal is to assist you in creating a transfer pricing strategy that is technically robust, based on solid economic theory, while practical to implement and adaptable as your business develops.

A comprehensive transfer pricing strategy can:

  • balance compliance, operational, and tax-efficiency needs.
  • protect the past by providing economic justification for any changes from the existing transfer pricing policy.
  • help reduce the implications for other taxes (e.g. customs duty, value-added, and trade taxes).

Compliance and documentation

KPMG can advise you on local legislative requirements and review your existing policies to help you determine whether they are compliant. We can help create a transfer pricing policy that complies with local legislation and is supported by a robust analysis. Our aim is to advise your company on policies and procedures that both meet your business and tax requirements and help reduce administrative costs.

Specifically, our team can assist you with:

  • drawing up fully compliant transfer pricing documentation at a global or local level, ensuring compliance with Action 13 requirements – including the Master File, Local File, and Country-by-Country report (“CbCR”).
  • reviewing existing documentation and CbCR to identify potential risk exposure areas and potential risk mitigation options.
  • managing and meeting your CbCR obligations in various jurisdictions (i.e., CbCR notifications, local filings etc.).
  • preparing benchmarking and economic analyses using the most appropriate transfer pricing methods to support the arm’s-length character transfer prices paid and received in the context of your intra-group transactions.

Transfer pricing audits

As the Belgian tax authorities are flooded with transfer pricing information and documentation following the rather recent requirement for qualifying taxpayers to file a Master File, a Local File (Form), and Country-by-Country Reports (and notifications), they decided to considerably invest in manpower to review all these documents (hereby assisted by software tools) and to perform audits on the detected issues.

We can assist in determining an effective strategy for responding to such challenges, providing robust economic analyses in support of your existing transfer prices, helping you prepare strong responses to detailed inquiries and supporting you during negotiations with tax authorities.

Where a tax adjustment leads to international double taxation, we can assist you in the national and international procedures (such as the mutual agreement procedure or arbitrage procedure) to claim double taxation avoidance with the relevant tax authorities.

Advance Pricing Arrangements, Rulings and Competent Authority discussions

An Advance Pricing Arrangement (“APA”) or Ruling offers significant advantages to multinationals by helping to reduce uncertainty, avoid disruptive audits (thereby lowering related audit compliance costs) and mitigate the risk of double taxation.

KPMG has extensive experience in:

  • Negotiating APAs / Rulings – We can assess the risk of a tax authority challenge to your transfer prices and advise whether an APA / Ruling is the right approach for you. Our team offers extensive experience in negotiating unilateral, bilateral and multilateral APAs as well as Rulings;
  • Dealing with competent authority claims – We can advise you on when such claims should be made, thus helping you achieve a tax-neutral position.

Value Chain Management

Taking time to examine the best ways of integrating tax planning into business operations through Value Chain Management can help companies and groups to enhance growth opportunities. This in turn can lead to operational efficiencies, increasing return on investments as well as reducing risk and costs.

KPMG can help businesses reevaluate their value chains and operating models to identify, assess, and execute business model improvements, from a strategic tax and transfer pricing perspective – which can lead to greater profitability and cash flow.  This may involve reviewing existing commercial and tax structures, such as central principal structures involving entrepreneurial principal entities with limited risk distributors and contract / toll manufacturers, and identifying a robust, tax efficient structure without compromising the arm’s length principle and transfer pricing economics.

Operational transfer pricing

Transfer pricing implementation requires significant integration and collaboration across many independent functional areas of an organization, including tax, finance and accounting, operations, and information technology. We can help companies integrate their transfer pricing policies in their day-to-day operations, improve the integrity of their intercompany accounting, increase operating efficiencies and reduce risk. We can assess your current-state environment against leading practices, design processes and controls, and implement enabling technologies.

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