OECD Discussion Draft on transfer pricing aspects of hard-to-value intangibles published
The OECD has published a discussion draft on the arm’s length pricing of intangibles when valuation is highly uncertain at the time of the transaction or the intangibles are hard to value. The discussion draft, released on 4 June 2015, is part of Action Item 8 of the OECD’s Base Erosion and Profit Shifting (BEPS)
OECD publishes Discussion Draft on cost contribution arrangements
On 29 April 2015, the OECD issued a Discussion Draft on the transfer pricing aspects of cost contribution arrangements (‘CCAs’) under Action 8 of the BEPS action plan. The Draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines: With respect to measuring the value of contributions to CCAs and the tax
EC presents proposal for mandatory automatic exchange of information on cross-border tax rulings within the EU
In a press release of 18 March 2015, the European Commission (“EC”) announced its Tax Transparency Package, including a proposal to broaden the scope of the EU Council Directive (2011/16/EU) on Administrative Cooperation in the field of taxation (known as the “DAC”). Mandatory exchange of information The EC has released its proposed modification to the
Belgium considers introducing mandatory transfer pricing documentation following the outcome of the BEPS Action Plan
The Belgian Minister of Finance, Johan Van Overtveldt, shared some new insights about the government’s ambitions in the area of transfer pricing as part of his reply to a parliamentary question on Wednesday 11 March 2015 (CRIV 54 COM 111 –Parliamentary Question no. 2774). The Minister referred to the OECD project in relation to Base Erosion
Belgian tax authorities initiate new wave of transfer pricing audits
The Belgian tax authorities have initiated a new wave of transfer pricing audits, similar to those initiated in 2013 and 2014. Multiple taxpayers have already received or will receive in the next few days an in-depth questionnaire that focuses on their transfer pricing arrangements. The request for information on intercompany transactions and activities of the
Impact of announced tax measures on Transfer Pricing
As previously announced, a number of new tax measures has been announced in the framework of the Belgian government formation and the budget for 2015. Some of these will also have an impact on transfer pricing: The plan is to invest heavily in data mining tools for case selection purposes. These are likely to be used for
Belgian VAT authorities publish new VAT practice note
The Belgian VAT administration has recently published a new VAT practice note n°14 /2014 dated 4 April 2014 (E.T. 120.000) on (electronic) invoicing. Said VAT practice note is retroactively applicable as from 1 January 2013. The VAT practice note stresses the importance for businesses of implementing appropriate business controls in order to guarantee the authenticity of origin, the integrity
PwC announces publication of study on EU Customs Union
We are pleased to inform you that PwC has conducted a study for DG TAXUD on the Evaluation of the Customs Union during the period 2012 – 2013. The study includes an analysis and evaluation of the EU Customs Union based on the data PwC collected from business stakeholders and public authorities (customs and other
