Recent news

1. Wednesday, 04 September 2024

   Tiberghien Economics at the ITR Transfer Pricing Forum

   On September 11 & 12, transfer pricing professionals from varying industries as well as international tax lawyers will gather in Amsterdam for the 2024 ITR World Transfer Pricing Forum.

   Kenny Van Tulder is scheduled as a speaker on Wednesday at 11h15 and will be sharing his valuable insights during the Global transfer pricing update: Geographic Roundtables - EMEA, Americas, APAC. 

   Feel free to learn more about the event, the agenda and how to register on following website. 

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2. Monday, 02 September 2024

   Top Tier Firm in the ITR World Tax rankings for 2025

   We are pleased to share that Tiberghien has been ranked as a Top Tier Firm in the ITR World Tax rankings for 2025. We are particularly proud to be Tier 2 for Transfer Pricing and would like to thank our clients, for their positive feedback and trusting us with their transfer pricing matters! For more information on these rankings, click here

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3. Thursday, 25 July 2024

   Modifications to the Belgian Transfer pricing documentation and reporting requirements

   The Royal Decree of 16 June 2024, published in the Belgian Official Gazette on 15 July 2024, introduces modifications to the transfer pricing forms 275.MF, 275.LF and 275.CBC NOT. This royal decree replaces the royalty decree of 28 October 2016 and will be applicable for financial years starting on or after 1 January, 2025.

    
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4. Thursday, 11 April 2024

   2024 transfer pricing audit wave

   The Belgian tax authorities recently initiated the 2024 transfer pricing audit wave, starting with a questionnaire an a pre-audit meeting. 

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5. Wednesday, 21 February 2024

   Transfer pricing update France and Italy

   (France) Already in 2023, the French government stated that their new plan to combat tax- and customs (‘public finances’) fraud would introduce new measures to strengthen transfer pricing control/audits among taxpayers. These measures have now been introduced into law by the French Budget Bill 2024 and are applicable as of 1 January 2024.

   (Italy) A legislative decree published on 12 January 2024 has changed the deadline for filing the corporate income tax return for fiscal years starting after 31 December 2023. This change also has an impact on transfer pricing and the so-called penalty protection regime for preparing transfer pricing documentation.

    

    
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6. Friday, 13 October 2023

   BEFIT, towards a common corporate tax framework in the EU ?

   BEFIT stands for “Business in Europe: Framework for Income Taxation” and is the object of a draft EU directive proposed by the European Commission on 12 September 2023 (the “Draft Directive”). The stated aim of the Draft Directive is to reduce the tax compliance costs of large groups by proposing a unified and streamlined approach in the determination of the tax base of their EU companies.

    
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7. Thursday, 12 October 2023

   Breakfast seminar on transfer pricing

   Intercompany financial transactions have been high on company’s and tax authorities’ transfer pricing agendas for several years.

    
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8. Monday, 10 July 2023

   2022 annual report of the Belgian ruling commission

   The Belgian ruling commission published its annual report for 2022 on 12 June 2023. It can be consulted here in Dutch and French. A couple of notable decisions in relation to transfer pricing and the innovation income deduction are discussed below.

    
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9. Tuesday, 27 June 2023

   Brazil’ legislator enacts new transfer pricing law

   On 15 June 2023, Brazil published a new law establishing a transfer pricing framework that is aligned with the OECD Transfer Pricing Guidelines (“OECD TPG”). Reforming Brazil’s transfer pricing (“TP”) rules has been discussed for a long time but the debate was intensified since Brazil’s application to join the OECD in 2017 . The new law includes among others the introduction of the arm’s length principle and the implementation of the TP methods in accordance with the OECD TPG.

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10. Tuesday, 14 March 2023

    Silicon Valley Bank – Key Take-aways for Transfer Pricing

    With the Silicon Valley Bank (“SVB”) all over the financial news, in the below, we briefly summarize the case and provide you the key take-aways from a transfer pricing perspective on internal banks of multinational groups.

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