The Belgian Tax Authorities have published a long awaited list of Frequently Asked Questions (FAQ) on their webpage dedicated to the Belgian Transfer Pricing documentation requirements. The FAQs are available in Dutch and French.
This publication is quite important as it provides further guidance on how to deal with the Belgian transfer pricing documentation requirements in case of e.g. joint ventures, acquisition and divestitures of a Belgian company and differences in reporting period between the ultimate parent entity of the group and a Belgian company.
It is also the first additional formal guidance from the Belgian tax administration since the publication of the Royal Decrees in the Belgian Official Gazette on 2 December 2016 that contain the various models of the forms Belgian entities need to use to submit the Masterfile, Local File and CbC Report.
Although this initiative from the Belgian tax administration is more than welcome, some (important) issues remain nevertheless unanswered or unclear, e.g. dealings of a foreign permanent establishment of a Belgian company etc., including aspects of the practical implementation thereof.
The FAQs can be found here.
See also our dedicated webpage and our relevant tax insights of 5 July 2016, 2 December 2016, 27 November 2017 and 23 April 2018 for a summary of the Belgian Transfer Pricing documentation requirements (qualifying companies, content of the forms, deadlines etc.).
For further insights and to understand the potential implications for your organization, please contact your local PwC contact or Xavier Van Vlem.