Belgian transfer pricing audits: increased manpower, new focus areas and enhanced cooperation on the horizon
Beginning in February of 2018, the Belgian tax authorities will initiate a new wave of transfer pricing (TP) audits. The central transfer pricing investigation team (TP Unit) is investing in additional manpower and changing investigation approaches to increase the effectiveness of audits. Taxpayers should also expect more scrutiny on TP matters from other tax departments,
Tax Ruling Service specifies “disproportional grant” of warrants or OTCs in two particular cases
In the past, the Tax Ruling Service has taken several decisions whereby it was not excluded that the grant of warrants/options on Beveks/Sicavs or the grant of quoted options could be considered as an improper use if such grant would be considered ‘disproportionate’ in comparison with the conventional attributed remuneration. The Tax Ruling Service never