tax

The Belgian Supreme Court ruled that income derived from a received abnormal or gratuitous benefit constitutes a minimum tax base

20 April 2016

If an intra-group transaction is considered as “abnormal or gratuitous” – i.e. not being arm’s length –, Belgian tax law prescribes a transfer pricing adjustment. An abnormal or gratuitous benefit received by a Belgian company from an affiliated enterprise cannot be offset against tax losses and other deductible items available to the Belgian company, such