Transfer pricing is a vital aspect of effective global tax planning for multinationals with cross border or domestic intercompany transactions.
Transfer pricing is a vital aspect of effective global tax planning for multinationals...
In October 2015, the Organization for Economic Co-operation and Development (OECD) released 14 final reports in relation to the 15 Base Erosion and Profit Shifting (BEPS) action points tackled in the 2013 BEPS action plan. European governments expressed their commitment to end BEPS and are eager to help shape and refine the plan. Now that the final reports have been issued, federal governments are making changes to their tax codes in order to be aligned with the new recommendations and regulations.
In Belgium, in line with the guidance provided by the OECD in Action Point 13 of its Base Erosion and Profit Shifting (BEPS) reports, the federal government has introduced the transfer pricing documentation requirements (through the Program Law of 1 July 2016 and the related Royal Decree dated 28 October 2016). This indicates a significant shift. Belgium is moving from an era where no transfer pricing documentation was required (unless requested in the context of a tax audit) to a formal transfer pricing documentation obligation which includes the electronic filing of all the documentation to be prepared. In addition, Belgian tax authorities have decided to take the tax audits of multinational groups to the next level. From now on, the Belgian tax inspectors will mainly focus on transfer pricing and complex international tax issues (resulting from, among others, the implementation of the Anti-Tax Avoidance Directive, “ATAD”).
Our multidisciplinary approach can help you manage your company’s transfer pricing issues by providing advice on planning, compliance and documentation, compliance dispute resolution, and practical implementation of your transfer pricing policy in Belgium and internationally. Our team of experts is ready to assist you with:
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