NEW TRANSFER PRICING OBLIGATIONS IN BELGIUM
28 December 2015
The Belgian Ministry of Finance has decided in its policy note of 3 December 2015 to adopt additional transfer pricing documentation obligations.
In particular, mutlinationals will be obliged to provide :
- A country-by-country report, which is to be enlcosed to the tax return of multinationals who realise a consolidated turnover exceeding EUR 750 M. In this report, the multinational enterprise provides information on its worldwide fiscal profit sharing policy, tax paid in established countries and all other relevant economical influences, such as geographical locations, a brief description of the business activities of each of the related companies in the group, etc.;
- A separate enclosure to the tax return mentioning intragroup transactions exceeding EUR 500,000 (as is already an obligation for payments exceeding EUR 100,000 to persons established in tax havens through a form 275F).
The Ministry also announced its intention to retain focus on transfer pricing audits and to reinforce its Transfer Pricing department in the next few years.
For more information regarding this topic, please do not hesitate to contact our Transfer Pricing specialists: