The impact of COVID-19 on routine profits
Evidencing downward adjustments for limited risk entities commands more than a quick browse through high-level macroeconomic trends. As many companies consider to adjust their transfer pricing (TP) policies as a result of the current economic situation, we’ve performed a robust macroeconomic analysis linked to some 180,000 company data points. The approach is rooted in work
EBITDA Interest Limitation Rule: New Circular Letter avoids unintended consequences when obtaining payment holidays
On 5 May 2020, the Belgian tax administration published its Circular Letter 2020/C/62 on specific payment holidays negotiated in the context of the COVID-19 crisis. More in particular, this circular accepts that certain loans will not lose their “grandfathered” status in case specific modifications are negotiated to loan agreements so to bridge temporary payment difficulties.
Belgian transfer pricing audits: new wave initiated – Update
Our newsflash of 25 March 2020 informed you about the upcoming new wave of transfer pricing audits and the requests for information that were sent out. In the meantime, and in particular in light of the Covid-19 pandemie, we were informed that the BTA has suspended the sending out of the requests for information. For
Belgian transfer pricing audits: new wave initiated
Last week, the Belgian tax authorities have initiated a new wave of transfer pricing audits. 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 Belgian company or branch is the
Long awaited Transfer Pricing Circular published
On 25 February 2020, the Belgian tax administration published Circular Letter 2020/C/35 on the 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 OECD TPG). This practice note is available in Dutch and French. The circular is the final version of a draft circular letter originally published by the
Tax Authorities have issued Circular Letter regarding the Group Contribution Regime
On 13 February 2020, a circular letter on the group contribution regime has been published (Dutch and French version). The group contribution regime, applicable as of financial year 2019 (assessment year 2020), enables Belgian companies and Belgian branches of entities located in the EER to transfer taxable profits to other affiliated Belgian companies/branches with the
Time to act as OECD/G20 Inclusive Framework moves forward on new tax rules
On the 31st of January 2020, after a two-day meeting held on 29 – 30 January, the OECD/G20 Inclusive Framework on BEPS issued a statement that updates the state-of-play regarding the work on tax challenges arising from the digitalization of the economy, and sets forth a revised work program on the Two-Pillar Approach. In this
The OECD releases its Transfer Pricing Guidance on Financial Transactions
The OECD has released its long-awaited final report on the transfer pricing aspects of financial transactions. The report will constitute the 10th chapter of the OECD Transfer Pricing Guidelines (as well as an additional section in Chapter I). It covers a wide range of financial transactions and provides guidance on critical aspects to be considered
