Recent news

  1. Monday, 14 November 2022

    Inflation – back for good?

    Is inflation back for good? A seemingly simple question, but apparently much harder to answer by politicians and central bankers alike. While the Fed is nervously trying to tame the inflation monster by increasing the key interest rates, the European Central Bank (“ECB”) initially was quite reluctant to do so (as its main concern was rather the national governments’ debt levels) and the false believe that the inflation hike was just a temporary issue. At first, the ECB commented that inflation was only fired up due to the higher energy prices as a reaction to the war in Ukraine. Now that the predicted inflation peak every month keeps on shifting to the next month, inflation looks much more persistent than initially anticipated (by ECB) with the latest Belgian inflation rates as per September 2022 well above 10%. According to the data below provided by the OECD, other countries are faced with similar percentages:

  2. Monday, 14 November 2022

    One deal, One party – the pro’s and con’s of a GP-led secondary (for both investors and private equity)

    In recent times, a cocktail of ample, free money and limited to no return on the fixed income markets, drove investors in search for yield towards private equity. These private equity funds typically have a lifespan of around 10 years. While, again in recent times, sales of portfolio companies was not a big issue considering valuations went up, taking into account the following:

    1. A booming equity market ensured that an Initial Public Offering (“IPO) was a valid option
    2. due to the significant increase of available money at the level of private equity funds, sales of a portfolio company to another private equity fund (or any other party) was a successful option considering the increase in deals and deals amounts
  3. Monday, 10 October 2022

    International Tax Update: BAPA manual published by the OECD

    The OECD Forum on Tax Administration has published on 28 September 2022 a manual on Bilateral Advance Pricing Arrangements, namely the Bilateral Advance Pricing Arrangement Manual (“BAPAM” or “Manual”). This BAPAM is part of the tax certainty work programme of the Forum on Tax Administration with as key focus “to guide tax administrations and taxpayers for streamlining the bilateral APA process through increased transparency and collaboration between competent authorities and taxpayers, and mitigating delays created by differences in individual jurisdiction’s BAPA processes”.

  4. Monday, 02 May 2022

    (When) Will transfer pricing in Brazil be more aligned with OECD standards?

    On 12 April 2022, the OECD and the Brazilian tax authority (Brazil's Receita Federal (‘RFB’)) met in view of a proposed new transfer pricing system, which would be more aligned with the OECD Transfer Pricing Guidelines (‘OECD TPG’). As current Brazilian transfer pricing rules contain important differences with the OECD TPG, such alignment would be interesting for multinational companies having a tax presence in Brazil, as such differences may result in tax uncertainty/increased risks during transfer pricing audits, inconsistencies in transfer pricing policies throughout the group and a higher administrative burden.

  5. Wednesday, 20 April 2022

    Breakfast seminars: Transfer Pricing

    In order to tackle a visit from the tax authorities on transfer pricing in an informed manner, the transfer pricing specialists of Tiberghien economics and the litigation team of Tiberghien are happy to share their knowledge and experiences.

  6. Thursday, 17 March 2022

    Stay on top of ever-changing local transfer pricing documentation requirements

    The Transfer Pricing documentation landscape is continuously evolving, whereby recently, there has been an increasing tendency of various countries updating and strengthening their transfer pricing documentation requirements. Considering these changes, it is important for internationally active groups to follow up on this fast-moving landscape and to make sure that no crucial deadline is missed.

  7. Thursday, 10 March 2022

    CBN guidance on (de)mergers with entities having negative net asset values

    On February 15th, the Belgian accounting standards boards (Comissie voor Boekhoudkundige normen – hereafter “CBN”) published additional guidance with respect to mergers and demergers of companies having negative net asset values. We note that advices approved and published by the CBN merely contain guidance and is not legally binding.

  8. Tuesday, 08 March 2022

    Updated Transfer Pricing Country Profiles published by OECD – Part 3

    Following our previous newsflashes regarding the updated transfer pricing country profiles published by the OECD (first batch in August 2021, second batch in December 2021), the OECD has released a third batch of updated and new transfer pricing profiles for 28 countries on 28 February 2022. This brings the total number of countries covered to 91. The updates include, in line with the first and second batches, two new sections that cover the transfer pricing treatment of financial transactions and the application of the Authorised OECD Approach (AOA) to attribute profits to permanent establishments.

  9. Monday, 31 January 2022

    Transfer Pricing audits in Belgium: Facts, figures and evolutions

    As the yearly transfer pricing audit wave was recently released by the Belgian tax authorities, in which Belgian taxpayers receive a (mostly) standardized, extensive request for information, it is a good moment to have a look at some recent developments as well as certain facts and figures linked to transfer pricing audits.

  10. Friday, 21 January 2022

    'New' 2022 OECD Transfer Pricing Guidelines: Bundling of earlier guidance

    The OECD published today the successor of the July 2017 edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD TP Guidelines”). This ’January 2022’ edition of the OECD TP Guidelines incorporates: