The Service for Advance Decisions (SAD) indicated, in line with previous years, that prefiling requests or requests that are not preceded by a prefiling, concerning transfer pricing or the innovation income deduction and that relate to the calendar year 2021 (fiscal year 2022), must be filed by 31 January 2022 at the latest.
This timing has been set to allow the SAD to grant a decision before the deadline for filing the non-resident/corporate income tax return.
To ensure an efficient processing of requests/prefiling requests, the SAD would like to receive documents including a presentation of the company concerned and its activities, a motivation for the envisaged transaction and a description of the method used along with the calculations.
For companies whose accounting year does not coincide with the calendar year, it is requested that prefiling requests or requests that are not preceded by a pre-filing be submitted in time, i.e. at least 8 months before the deadline for the submission of the non-resident/corporate income tax return.
For more information, don't hesitate to contact:
Tine Slaedts - Partner (tine.slaedts@tiberghien.com)