Upcoming changes to the Belgian transfer pricing documentation forms
Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities since financial year 2016. A Belgian company (or a branch) that is a part of a multinational group will have to submit the form 275 LF (Local file) and the form 275 MF (Master file) in case one of the following
The UN Ad Hoc Committee released the Zero Draft ToR for the UN Tax Framework Convention for Public Consultation
On 7 June 2024 the Bureau of the Ad Hoc Committee (‘the Bureau’) released a Proposal for the Zero Draft Terms of Reference for the United Nations Framework Convention on International Tax Cooperation (‘the Draft Terms’). UN Member States and other stakeholders are invited to provide comments by 21 June 2024. These comments will ultimately
Royal Decree on Public Country by Country Reporting published
On 6 June 2024, the Royal Decree on public country by country reporting (PCbCR) was published in the Belgian official gazette (See also our earlier messages on the introduction of public country by country reporting in Belgium of 4 June 2021 and 17 November 2023). This Royal Decree modifies the Royal Decree of 29 April
OECD Published Guidance on Amount B
On 19 February 2024, the OECD published a report which aims to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities (the Report) (also known as Amount B under Pillar One). The first draft guidance and call for input dates back from late 2020. Quite some time
Belgium and The Netherlands agree on employees working from their home location
On November 23, 2023, the Competent Authorities (CA) of Belgium and The Netherlands signed an agreement* clarifying when a permanent establishment (PE) exists for the employer in the other country if employees are working from their home location in that other country. This agreement provides welcome additional guidance on the cases in which an employee
Draft law on public country-by-country reporting in parliament
Introduction In our previous newsflash regarding the public country-by-country reporting (PCbCR) directive, we informed you that EU member states must introduce the directive in their domestic legislation by 22 June 2023 at the latest. Belgian PCbCR draft law On 10 November 2023, the Belgian draft law was finally published. As per the draft text, companies
German- Belgian Colloquium on global tax reform: a status update on the OECD Two Pillar Approach
On May 23rd, 2022 the Belgian and German tax authorities organized a colloquium on the two-pillar approach. The colloquium was held in Brussels and was hosted by Mr Hans D’Hondt, Chairman of the Management Committee of the Belgian Federal Public Service Finance. The colloquium was opened by Mr D’Hondt and Mr Martin Kotthaus, Ambassador of
Public Country-by-Country Reporting Directive enters into force soon
With our newsflash of 16 November 2021, we informed you of the formal approval of the public country-by-country reporting (PCbCR) directive on 11 November 2021. The directive is published in the Official Journal of the EU on 1 December 2021; it enters into force on the 20th day after its publication. Member states must introduce
