Recent news

  1. Thursday, 29 October 2020

    Non-consensus guidance on application of arm’s length principle for intercompany loans…

    In July 2018, under the mandate of the Report on Actions 8-10 of the Base Erosion and Profit Shifting (“BEPS”) Action Plan (“Aligning Transfer Pricing Outcomes with Value Creation”), the OECD Working Party 6 published a non-consensus discussion draft on financial transactions. Although there were many comments and fundamental issues raised by various parties, the differences between the so-called non-consensus draft and the final report are rather limited (we refer in this respect to an article published by International Tax Review1). Furthermore, it was already clear back in 2018 that countries participating in the OECD Working Party 6 could not reach consensus, the release date of the public discussion draft being behind schedule provided an indication (please find our initial comments on that non-consensus draft here).

  2. Thursday, 15 October 2020

    Uiterlijke indieningsdatum van prefilingaanvragen of aanvragen die niet voorafgegaan zijn door een prefiling

    De DVB wenst er de aandacht op te vestigen dat prefilingaanvragen of aanvragen die niet voorafgegaan zijn door een prefiling, m.b.t. verrekenprijzen of de aftrek voor innovatie-inkomsten (of octrooi-inkomsten), en die fiscale uitwerking hebben in een aangifte in de vennootschapsbelasting (of BNI/Ven.) welke waarschijnlijk eind september 2021 dient ingediend te worden, uiterlijk tegen 31 januari 2021 op de DVB dienen toe te komen zodat er nog een beslissing kan afgeleverd worden vóór de uiterste indieningstermijn van de aangifte in de vennootschapsbelasting (of BNI/Ven.).

  3. Tuesday, 13 October 2020

    WTS Global Transfer Pricing Newsletter #2

    In this latest edition of the WTS Transfer Pricing Newsletter, our colleagues from 13 countries provided an update on recently introduced legislations and cases. Additionally, developments in the field of transfer pricing, due to the economic and social impact of the ongoing COVID-19 pandemic are presented.

  4. Tuesday, 13 October 2020

    Detailed transfer pricing form in Belgium postponed

    The deadline of the corporate income tax returns has been extended for the second time by the Minister of Finance, initially set 24 September 2020 (for companies with a financial year-end at 31 December 2019), first time extended to 29 October 2020, with the new due date currently set 16 November 2020. This extension has been granted after massive requests of accounting firms that were - and still are - overloaded with work due to the exceptional circumstances caused by the covid-19 crisis. More in particular, companies have been requesting assistance from accounting firms with regard to various measures taken by the Belgian tax authorities to support Belgian companies, amongst others, obtaining the appropriate support measures of the Belgian government, requesting deferment of payment of banks, apply for legal protection or bankruptcy, etc. This new postponement should allow accounting firms to submit the personal and corporate income tax returns in a (postponed) timely manner.

  5. Thursday, 01 October 2020

    TIBERGHIEN ECONOMICS!

    A NEW, YET FAMILIAR BRAND TO UNDERSCORE OUR HOLISTIC VIEW ON OUR CLIENT’S CHALLENGES AND ASPIRATIONS.

    We are excited to announce that, as from now, T/A economics will be deploying its services as Tiberghien economics. Exactly 5 years after we established our privileged partnership with the highly regarded BeLux law firm Tiberghien, and based on the successful experiences we had in jointly serving our mutual clients, we felt it natural to take this next step, in order to give the market a strong signal that Tiberghien lawyers and Tiberghien economics will further intensify their network cooperation to address the challenges of their clients with a multidisciplinary mindset.

  6. Tuesday, 01 September 2020

    The Transfer Pricing Law Review - Chapter 2: Belgium

    Although the arm’s-length principle, which forms the basis of the framework of transfer pricing rules, has had a long international history, it was only explicitly introduced into Belgian legislation in 2004. The Belgian legislature used the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Guidelines (the OECD Guidelines) and the OECD Model Tax Convention as inspiration.

  7. Friday, 17 July 2020

    Are you leveraging from the available R&D tax incentives?

    Belgium offers a full range of tax incentives enabling companies to structure their R&D activities, as well as the valorization of the intellectual property (IP) resulting from R&D activities. This comprehensive R&D regime consists of tax deductions on qualifying IP income, deductions on R&D investments and (refundable) tax credits, cash savings from partial exemption from withholding tax for qualified researchers and full tax exemption of R&D subsidies. 

  8. Thursday, 16 July 2020

    Circular 2020/C/95 FAQ innovation income deduction published

    The Circular 2020/C/95/Frequently Asked Questions (FAQ) (Dutch version / French version) on the Belgian innovation deduction was published on July 8, 2020. The innovation deduction provides for a deduction of 85% of the net income from intellectual property (IP). This results in an effective tax rate of 4.4% (2019) and 3.8% (as from 2020) on the net income.

  9. Monday, 13 July 2020

    Detailed transfer pricing form in Belgium postponed

  10. Friday, 26 June 2020

    Prepare for detailed transfer pricing form in Belgium

    The filing date for the local file form (form 275 LF) as part of the mandatory transfer pricing documentation in Belgium is approaching for a large amount of Belgian entities that form part of a multinational group.