EU Commission finds that Luxembourg granted unlawful State aid to Amazon
On 26 February 2018, the European Commission (EC) published the non-confidential version of its final decision issued on 4 October 2017 in the Amazon State aid investigation opened in October 2014. According to the decision, in the EC’s opinion, Luxembourg’s tax treatment of Amazon gave rise to State aid in the amount of up to
Upcoming due date for the electronic filing of the Master file and the Country-by-country notification: 31 March 2018
For the first year of filing of the new transfer pricing documentation, the Belgian tax authorities have granted an administrative extension for the Master file and the Country-by-country notification till the end of March. What? A Belgian entity of a multinational group exceeding at least one of the following criteria needs to submit a Master
Belgian transfer pricing audits: increased manpower, new focus areas and enhanced cooperation on the horizon
Beginning in February of 2018, the Belgian tax authorities will initiate a new wave of transfer pricing (TP) audits. The central transfer pricing investigation team (TP Unit) is investing in additional manpower and changing investigation approaches to increase the effectiveness of audits. Taxpayers should also expect more scrutiny on TP matters from other tax departments,
Belgian corporate tax reform enacted by Parliament
On 22 December 2017, the Belgian Parliament approved the major corporate tax reform announced in July. The final Act is expected to be published still before the year end. In that way, the majority of the measures can come into force on 1 January 2018. The corporate tax reform which is now voted is part
ECOFIN Council’s publication of the EU list of third country non-cooperative jurisdictions in tax matters
On 5 December 2017, the ECOFIN Council published its conclusions on the EU common list of (third country) non-cooperative jurisdictions in tax matters, also referred to as the ‘blacklist’ consisting of 17 jurisdictions. This initiative forms part of the EU’s broader agenda on furthering tax transparency, fair taxation and the implementation of anti-BEPS measures with the
Alert: Do not forget the Belgian transfer pricing documentation requirements
The purpose of this message is to remind you of the Belgian transfer pricing (“TP”) documentation requirements that qualifying companies have to meet in the near future. See https://www.pwc.be/transferpricing and the relevant tax insights of 14 June 2016 and 15 December 2016 for a summary of the Belgian TP documentation requirements (qualifying companies, content of the
EU Directive on Tax Dispute Resolution Mechanisms formally adopted
On 10 October 2017, the ECOFIN Council formally adopted a Directive on tax dispute resolution mechanisms in the EU. The objective is to establish more effective and efficient procedures within the EU. The Directive builds on the existing Convention 90/436/EEC on the elimination of double taxation in connection with the adjustment of profits of associated
EU Commission takes next steps against Ireland and Luxembourg in Apple and Amazon State aid cases
On October 4, 2017, the European Commission (EC) continued its ongoing challenges to Member States’ transfer pricing tax regimes by advancing two high profile cases to the next stages. In the Apple case, the EC referred Ireland to the Court of Justice of the European Union (CJEU) for failing to enforce an August 2016 State aid recovery decision,
