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:
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:
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:
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.
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:
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.
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.