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.

T/A economics is proud to announce Tine Slaedts joining as a partner. Tine brings a wealth of experience (+23 years) to the team.

Tine Slaedts started her career at the Belgian ministry of finance as a tax inspector, and subsequently went into consulting at the Big4. Most of the T/A economics team members have worked together with Tine at EY Belgium, where she helped managing the transfer pricing practice in Belgium and also in South Africa for some time in a stint of almost 12 years. As from April 2013, until recently, she has been responsible for building the transfer pricing practice and team at BDO. 

The first issue of the WTS Global Transfer Pricing Newsletter provides you with an update on the recent news and cases in the field of transfer pricing in 14 countries as well as an OECD update on Pillar 1.

That Covid-19 will have a significant impact on the financing of companies is quite clear (for more details on tackling financial distress, click here). While some businesses / sectors struggle with (minor) liquidity issues, others face more severe issues as the lockdown means a complete standstill to oppose the Covid-19-crisis, which might bring them in a situation of financial distress and render them insolvable in the end.

Given that the stock market, as a leading economic indicator, anticipates economic turning points, the sharp decline and volatility over the last weeks of several stock indices globally, clearly indicates that the Covid-19 crisis will have a significant economic impact. It is, therefore, not unthinkable that (groups of) companies will find themselves facing pertinent liquidity issues that might even evolve into solvability issues.

Yesterday, the Belgian tax administration published the Circular Letter “Transfer Pricing” (Circular Letter 2020/C/35). This document is the final version of the Circular Letter following the draft Circular Letter that was initially published on 9 November 2018, to which stakeholders were invited to submit comments (in two rounds, respective deadlines of December 2018 and June 2019).

The Inclusive Framework on BEPS (“IF”) members strongly support reaching a multilateral agreement with respect to Pillar One and Pillar Two as well as recognizing the concurrent work, on a without prejudice basis, on the two pillars. As a result, these members affirm their commitment to reach an agreement on a consensus-based solution by the end of 2020. In light of the above, the IF published a statement based on technical work provided by the Working Parties, as well as comments from the public consultation round and discussions at a number of Steering Group meetings. The IF has agreed upon an outline of the architecture of a Unified Approach on Pillar One which will serve as a basis for negotiations. Additionally, it welcomed the progress made on Pillar Two. This statement can be found at http://bit.ly/2S9WrZh

On 9 October 2019, the OECD published a proposal for a “unified approach” to the nexus and profit allocation challenges arising from the digital economy.

The EU General Court Tuesday ruled in favor of Starbucks and in disadvantage of Fiat on the European’s Commission claim that both companies received illegal state aid from the Dutch, respectively Luxembourg tax administration. Notwithstanding the general expectation exists that both cases will be further dealt with in appeal, they will be intensively analyzed, in particular by Apple whose case is still under examination.