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
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
Taxpayer relationship and tax audits in Belgium: what can we expect following the Belgian Minister of Finance’s policy note?
The Belgian Minister of Finance, Vincent Van Peteghem, has made his first official statements on the ambitions of the new government De Croo I in relation to the SPF/FOD Finance. Minister Van Peteghem, also in charge of the Coordination of the Fight against Fraud, presented his policy note on 4 November 2020 to the Belgian
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
Tax dispute resolution – Belgium obtains positive peer review on its Mutual Agreement Procedure practice
Background Improving dispute resolution mechanisms as regards the application and interpretation of tax treaties is high on the agenda of the OECD and a number of countries. Under BEPS Action 14, there is a broad commitment to implement a minimum standard to strengthen the effectiveness and efficiency of Mutual Agreement Procedures (“MAP”). One of the
On 2 May 2019, Belgium completed the implementation process of the Directive on tax dispute resolution mechanisms in the EU (Council Directive 2017/1852 of 10 October 2017). This enhanced procedure for resolving cross-border direct tax disputes puts taxpayer rights at the forefront, has a broader scope of application as well as an obligation for the
The EU Joint Transfer Pricing Forum (“EU JTPF” or “the Forum”) recently published its report “A coordinated approach to transfer pricing controls within the EU”, which aims to address the lack of guidance on bilateral and multilateral transfer pricing audits. The objective of the report, inspired by a number of successful pilot cases, is to
The Large Enterprises Division of the Belgian tax administration (“LE Division”) announced the launch of a two-year pilot project on cooperative tax compliance (Cooperative Tax Compliance Program – “CTCP”). The program is aimed at transforming the traditional approach of ex-post tax investigations towards a system of proactive, real-time and constructive dialogue on the tax affairs of corporates.