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
Tax Bites Podcast – New Administrative Guidance on Pillar 2 and new timeline Pillar 1 – Amount A
A first critical look at the items addressed by the Administrative Guidance! In this episode, we share our first impressions of the Administrative Guidance on Pillar 2 published by the OECD on Monday 18 December 2023. A wide range of issues related to transitional safe harbours, the GloBE Rules and the Commentary are addressed in
Tax Bites Podcast – Future-proofing your statutory reporting function (Part 5)
Future-proofing your statutory reporting function: managing transformations in the STAT & tax function In this fifth and final episode of our mini-series, we want to bring it all together. How do companies deliver in practice on the transformation of their STAT & tax function. How do they start such transformation projects? How do they manage
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
Tax Bites Podcast: Amount B is back – what does it mean?
Amount B is back – what does it mean? In this episode the speakers will give an update on the current status and content of Amount B, what it means for businesses, next steps to consider along with some crystal ball predictions on the likelihood and breadth of the impact. About the speakers: Gilles Franssens
VAT & Digital Services: European Commission on NFTs and Implications from OnlyFans EUCJ Case
VAT Treatment of NFTs: The European Commission has published Working Paper 1060, offering initial insights into the VAT treatment of non-fungible tokens (NFTs). The document aims to collect input from Member States to establish a consensus on NFTs’ VAT treatment. It emphasizes the complexity of NFTs, highlighting the following points: NFT VAT treatment necessitates case-by-case
Power Purchase Agreements and Contracts for Differences: unraveling the complexity!
The EC’s Electricity Market Reform Proposal The European Commission (EU) has proposed a reform to its electricity market design. The idea behind the reform is to accelerate the transition to renewables and reduce the dependency on Russian gas before next winter (1). The reform also aims to make consumer bills less dependent on volatile fossil
