1. Friday, 23 March 2018

    OECD - newsflash

    On March 22, 2018, the OECD released the report ‘Additional Guidance on the Attribution of Profits to Permanent Establishments’. This report follows the final report on ‘Preventing the Artificial Avoidance of Permanent Establishments Status’, which was released earlier as part of action point 7 of the BEPS project.

  2. Wednesday, 20 December 2017

    UBO register very close to be introduced in Luxembourg !

    Following the adoption of the fourth EU anti-money laundering directive (2015/849/EC, the “Directive”) which aim is to prevent money laundering and terrorism financing by means of, inter alia, introducing central registers identifying the ultimate beneficial owner(s) (“UBOs”) for certain Luxembourg entities, two draft bills of law were introduced on 6 December 2017 and presented to the Luxembourg Chamber of Deputies. Both bills are presently undergoing their parliamentary journey, expected to be implemented in the course of 2018.

  3. Tuesday, 19 December 2017

    WTS Transfer Pricing Newsletter December 2017

    The WTS newsletter summarizes new developments in the field of TP for 10 countries and has been prepared by local TP experts within the global WTS-network.


  4. Tuesday, 12 December 2017

    Update on Electronic filing of Belgian Transfer Pricing documentation

    The Belgian tax authorities have granted an extension on the administrative deadline until 31 March 2018 regarding the filing of the Master file (275 MF), the Country-by-Country report (275 CBC) and Country-by-Country notification for 2018 (275 CBC NOT).

  5. Wednesday, 15 November 2017

    Transfer pricing documentation is key

    According to Dutch transfer pricing legislation (article 8b of the Dutch Corporate Income Tax Act), Dutch tax payers need to have documentation available that demonstrates the arm’s-length nature of transfer prices applied to intra-group transactions. This transfer pricing documentation should be part of a taxpayers’ administration.

  6. Thursday, 05 October 2017

    WTS Transfer Pricing Newsletter October 2017

    Andy Neuteleers, Michiel Boeren and Jean-Luc Dascotte (Tiberghien) contributed to the WTS newsletter for October 2017 with an article on Luxembourg's new IP regime as of 2018.

  7. Tuesday, 03 October 2017

    World Transfer Pricing 2018: T/A economics is 'firm to watch'

    We are happy to announce that T/A economics is mentioned as 'firm to watch' in the World Transfer Pricing 2018 rankings for all three Benelux countries.


  8. Thursday, 17 August 2017

    Transfer Pricing Documentation - Belgian Local File as integral part of the tax return: Procedural issues?

    As we reported earlier, Belgium has adopted formal transfer pricing documentation rules.

  9. Friday, 11 August 2017

    Luxembourg introduces new IP tax regime

    On 4 August, the Luxembourg Government submitted its long awaited bill of law for the introduction of a new tax regime in order to increase intellectual property (“IP”) developments (the “Bill of Law”). The new regime follows just over one year after the Luxembourg government abolished its former IP regime as from 30 June 2016 (subject to grandfathering rules in effect until no later than 30 June 2021). Once the bill of law is enacted, the new IP regime should become effective as of 2018.

  10. Monday, 31 July 2017

    Cyprus introduces new transfer pricing rules for intra-group financing activities

    In a Circular issued by the Cyprus Tax Authorities on 30 June 2017, new transfer pricing rules have been implemented for companies carrying out intra-group financing activities. The Circular is effective immediately and replace the former Minimum Margin Scheme regime. The Circular contains requirements regarding substance, risk/equity and arm’s length compensation.

    The new rules for intra-group financing companies in Cyprus are largely similar to the rules implemented in Luxembourg at the beginning of this year.