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,
Protocol to Belgium-Switzerland Double Tax Treaty enters into force
According to the Swiss Federal Department of Finance the additional protocol to the Double Tax Treaty (‘DTT’) between Belgium and Switzerland, that has been signed on April 10, 2014 has entered into force as of July 19, 2017 and will generally apply as from January 2018. In general terms, the protocol brings the current DTT,
Belgian tax reform reduces corporate rate to 25% and introduces fiscal consolidation
On 26 July 2017, the federal government reached an agreement on an important tax, economic and social reform package. A significant gradual reduction in the corporate income tax rate to 25% in 2020 and fiscal consolidation are key components of the package. The agreement preserves the notional interest deduction. The tax reform is built around
