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  • Transfer pricing documentation forms published in the Belgian State Gazette

Transfer pricing documentation forms published in the Belgian State Gazette

Tine Slaedts , Partner |

02 December 2016

The forms that allow companies to comply with the new Belgian transfer pricing documentation requirements have been published in the Belgian State Gazette of 2 December 2016.

Documentation requirements

The Program act of 1 July 2016 introduced mandatory transfer pricing documentation requirements for certain multinationals. The reporting requirements have 3 objectives:

  • ensuring that taxpayers give appropriate consideration to transfer pricing requirements in establishing prices and other conditions for transactions between associated enterprises and in reporting the income derived from such transactions in their tax returns;
  • providing tax administrations with the information necessary to conduct an informed transfer pricing risk assessment; and
  • providing tax administrations with useful information to employ in conducting an appropriately thorough audit of the transfer pricing practices of entities subject to tax in their jurisdiction, although it may be necessary to supplement the documentation with additional information as the audit progresses.

Three-tiered reporting

The documentation requirements consist of a three tiered reporting scheme:

  • a Master file containing standardized information relevant for all MNE group members;
  • a Local file referring specifically to material transactions of the local taxpayer; and
  • a Country-by-country report containing certain information relating to the global allocation of the MNE’s income and taxes paid together with certain indicators of the location of economic activity within the MNE group.

Forms

The forms to comply with the documentation requirements have been published in the Belgian State Gazette of 2 December 2016:

Contact

Should you have any questions on this topic or require further assistance, please do not hesitate to contact your regular BDO advisor or one of the members of the BDO Transfer Pricing team:

  • Tine Slaedts – Head of transfer pricing BDO Belgium – +32 (0)2 778 01 00 – [email protected]