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
Tax Bites Podcast – The Belgian government negotiations: what’s on the table?
The Belgian government negotiations are ongoing as we speak: what is in the ‘Nota De Wever’? Get a comprehensive overview from our experts in the latest edition of the tax bites podcast. Our experts reflect on how this can impact groups with Belgian activities. About the speakers Bart Van den Bussche Tim Van Sant Pieter
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
Pillar 2 notification: Administrative tolerance until 16 September
On 29 May 2024, the Royal Decree was published requiring Belgian entities of a Multinational Group to register with the Crossroads Bank of Enterprises (KBO or BCE) in order to comply with the Pillar 2 compliance formalities within 30 days after the first day of the first year in scope of Pillar 2 (or before
OECD issues a fourth package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 17 June 2024, the OECD released the fourth set of Administrative Guidance on GloBE rules, with the intention of clarifying the operation of these rules. This package follows the Administrative Guidance sets released in February, July and December last year. It is the first package of Administrative Guidance following the publication of the Consolidated
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
Tax Bites Podcast – What’s going on at the UN? The draft Terms of Reference for negotiating a Framework Convention on International Tax Cooperation
In this episode, we share our first impressions on the ‘Zero Draft’ Terms of Reference (ToR) for a UN Framework Convention on International Tax Cooperation released by the United Nations (UN) on 7 June 2024. Furthermore, we provide a brief overview of other important international and European tax developments. Tune in to get our first take on
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
