How key interest rate cuts and stabilising inflation might impact your transfer pricing policy
The past few years the financial markets have been characterised by a significant increase in interest rates battling the surge in inflation throughout the world. Since the arm’s length principle requires intercompany transactions to appropriately reflect current market conditions, these exogenous elements have led companies to update their financing policies and more specifically their transfer
Short-term deposits volumes are peaking in the Euro Area. How can an internal cash pool play a role?
Recent data published by the European Central Bank (“ECB”) indicates that the volume of short-term deposits made by non-financial companies (“NFCs”) in the euro area is reaching its peak. Similar trends are observed from the intra-group perspective, when international groups opt for an internal cash pool as one of the cash management solutions. In order
External financing is increasingly more difficult to obtain. How does it impact transfer pricing policies?
According to the latest update of the quarterly bank lending survey of the European Central Bank (“ECB”), the loan application rejection rate within the Eurosystem continued to increase during the first quarter of 2024, albeit at a slower rate than the previous quarter. In addition, Euro area banks reported a small further net tightening of
Arm’s length character of interest rates on intercompany loans
In recent years, the Belgian Tax Authorities (BTA) have intensified their focus on the (intercompany) financing arrangements of MNE groups. Some recent Belgian case laws offer valuable insights into the approach that the BTA and the Courts adopt when assessing the arm’s length character of intercompany financing conditions. Stay informed and adapt strategically! Judgment of
Implication of rising interest rates on the intercompany financing arrangements
The current upward trend in interest rates within the financial markets and the associated rise in borrowing costs can have a significant impact on the (intercompany) financing structures across MNE groups. From an arm’s length perspective it is essential that the terms and conditions of the intercompany transactions reflect third party dealings and market circumstances
New circular letter published on 30% EBITDA rule
On 12 January 2023 a new circular letter (2023/C/8) was published regarding the 30% EBITDA regulation (Dutch/French version). Over the past few years, the Belgian tax authorities have periodically published guidance on the interpretation of the 30% EBITDA rule. The new circular letter is intended to summarize the guidance that is currently available to provide
Tax Bites podcast: EU commission proposal to tackle the debt-equity bias in taxation (DEBRA)
In this week’s podcast, our speakers discuss the content of the proposal and assess which businesses will be impacted. They’ll explain the allowance on equity and interest limitation, linking this to other pending EU proposals. About the speakers: David Ledure, PwC Belgium Partner and leader of the global PwC Financial Transactions network Jean-Philippe Van West,
Update of the Belgian EBITDA rule provides opportunities for infrastructure and energy sector
Recently the Belgian legislator published a Royal Decree containing some clarifications on the repair law of 20 December 2020 containing changes to the 30% EBITDA rule. As mentioned in our previous Newsflash of 6 January 2021, the Belgian legislator published on 20 December 2020 new legislation in order to address criticism of the European Commission
