News articles written by Bram Markey

New provisions grant judicial police powers to Belgian tax inspectors to combat fraud

11 April 2022

The law of 17 March 2022 regarding various fiscal provisions to combat fraud has recently been published and adopted. It includes new tax provisions that remove the existing legal obstacles for officials of the Belgian tax administration to participate in judicial investigations. This law provides for a new legal framework that allows designated tax authority officials to

Investigation period for direct taxes soon prolonged without distinction between an ordinary investigation and a fraud investigation?

31 March 2022

A legislative proposal has been submitted to the Belgian Parliament with a view to harmonising the investigation and assessment periods for income tax and VAT. The proposal primarily looks to amend the legal provisions relating to the investigation period for direct tax matters. Currently, the normal investigation period for income tax is 3 years. This

EU cooperative compliance project for transfer pricing announced

14 October 2021

The European Commission (EC) has recently published guidelines on the European Trust and Cooperation Approach (ETACA), a pilot project on cooperative compliance within the EU specifically focusing on transfer pricing risks for large multinationals.  The ETACA pilot was already announced in the Action Plan for fair and simple taxation supporting the recovery strategy (see also

Tax Controversy Solutions: Insights into more than 75 countries at your fingertips

1 February 2021

Tax authorities around the globe are heavily engaged in tax audits, with pressure being exerted on tax enforcement and collection processes. Joint audits and international exchange of information is fueling complexity with each country varying in its focus areas, approach and dispute resolution processes. How our Tax Controversy Solutions can help? The PwC Tax Controversy

The OECD publishes its guidance on the transfer pricing implications of the COVID-19 pandemic

18 December 2020

During the outbreak and spreading of the COVID-19 pandemic, many businesses faced or are facing significant cash flow constraints, disruption to their supply chains, or even forced (temporary) closing for business. The long-awaited OECD guidance on the transfer pricing implications of the COVID-19 pandemic was finally published on 18 December 2020. A plea for practical

Belgian tax audits: increased focus on passive income streams and international cooperation

26 June 2020

The recent developments in the international tax world are clearly finding their way into the Belgian tax investigation practice. PwC observes a significant increase in tax audits in which the Belgian tax authorities are focusing on passive income flows (dividend, interest and royalty) and alleged tax abuse through the involvement of intermediary entities.  A number