Recent news

  1. 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.

  2. 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.

  3. 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.

  4. 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.

  5. 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.

  6. 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.

  7. 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:

  8. Wednesday, 12 January 2022

    Updated Transfer Pricing Country Profiles published by the OECD – Part 2, including Belgium

    Further to our previous newsflash regarding the updated transfer pricing country profiles published by the OECD in August 2021, the OECD has released a second batch of updated and new transfer pricing country profiles for 21 countries on 13 December 2021. This brings the total number of countries covered to 63. The updates include, in line with the first batch, 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. The OECD indicated that more updates to the transfer pricing country profiles are expected in the first half of 2022. We will keep you posted on updates.

  9. Friday, 07 January 2022

    The ultimate guide to get you through a transfer pricing audit

    Did you or your company recently have to deal with a transfer pricing audit? If not, there is a good chance you will be faced with one soon. The number of transfer pricing audits (TP audits) has increased in recent years and the Special Tax Inspectors (BBI/ISI), like real “fraud hunters”, are paying more and more attention to this matter.

  10. Wednesday, 17 November 2021

    Public Country-by-Country Reporting takes last hurdle in legislation process

    On 11 November 2021, the European Parliament approved the implementation of what is commonly referred to as the public country-by-country reporting (CbCR) Directive.1 This formal approval of the European Parliament came after the recent publication of the position of the European Council.