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
Corrections to previously filed CbC Reports
On July 30th 2019, the Belgian Tax Authorities (“BTA”) communicated that the portal MyMinfin has been opened for the submission of corrections to Country-by-Country Reports (“CbCR”) filed in previous years. In addition, the BTA have published practical guidelines and examples for reporting entities on how to report these corrections to previously filed CbCR. These guidelines
Circular 2019/C/14 – Addendum to the circular 2017/C/56 containing additional guidance on the transfer pricing documentation penalty regime
On 8 February 2019, an addendum to the circular was issued containing additional guidance on the transfer pricing documentation penalty regime. General All companies and permanent establishments must prepare transfer pricing documentation unless they meet certain thresholds for exemption from filing documentation. Failing to file (in due time) the transfer pricing documentation (i.e. country-by-country report
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
European Parliament Committees approve public Country-by-Country Reporting proposal
Further to the work of the OECD in the framework of the BEPS project, the European Parliament’s Economic and Monetary Affairs and Legal Affairs (ECON/JURI) committee members adopted on Monday 12 June 2017 their joint report on the EU Commission’s draft public CbCR Directive (The consolidated committee report is not yet published, but should be
Transfer Pricing Documentation – Forms and guidance published
Today, the Royal Decrees that contain the various models of the forms Belgian entities need to use to submit the Master File, Local File and CbC Report were published in the Belgian Official Gazette. This is the closing stone of the formal introduction of transfer pricing documentation requirements into Belgian tax law. Together with the
Parliament has approved Belgian Transfer Pricing Documentation Requirements
On 29 June 2016, the Belgian Parliament adopted the ‘programme law’ (introduced on 2 June 2016) that contains the introduction into Belgian tax law of specific transfer pricing documentation requirements (published in the Belgian Official Gazette of 4 July 2016). These requirements are based on Action 13 of the OECD /G20 BEPS Project. See our post
OECD publishes guidance on implementation of Country-by-Country Reporting
On 29 June 2016, the OECD released its Guidance on the Implementation of Country-by-Country Reporting (CbCR). According to the OECD press release, this is “a new step in its continuing efforts to boost transparency in international tax matters”. After the G20 leaders gave their approval regarding the final BEPS Package in November 2015, the focus