• Transfer Pricing

    ‘I’m fairly certain that my inter-company pricing is at arm's length,
    because I have been applying the same method consistently for ten years.
    So the chances of a tax inspector making any adjustments to
    my inter-company pricing would be rather slim, right?’

Transfer Pricing

Growing national and international interest in transfer pricing

Are you aware of the impact that the most comprehensive upheaval of international taxation in decades - the new ‘BEPS’ regulations - will have on your business? And on your transfer pricing policy in particular? The fact that some companies formerly dared to use - or abuse - transfer pricing to shift profits to countries with lower tax rates has tightened the regulations - and the vigilance of tax authorities - considerably. The number of transfer pricing audits is rising exponentially.

More than 250 professionals active in the field of transfer pricing

BDO’s global network identifies tax-related risks and opportunities. After all, why invest your own time or build up your own expertise in this field? And it is exactly because this subject matter is so complex that we in Belgium have a specialised and dedicated team: not one-track mind specialists, but experts who will actively listen to you, with experience across several sectors. They are people who - just like you - continually ask themselves if an idea or recommendation can be implemented in practice. People who enjoy daily contact with more than 250 professionals in the international BDO network who are active in the field of transfer pricing.

BDO will help you with what you’re looking for:

  • A detailed analysis of your transfer pricing risks
  • Documentation relating to the ‘inter-company’ pricing of goods, service, interests, royalties, etc.
  • The optimisation of your group’s tax position: matching transfer pricing to the operational activities of the companies within your group
  • Assistance during transfer pricing audits and procedures in order to avoid potential double taxation
  • Support in the compilation of a file with regard to the deduction for patent income
  • Proactive safeguarding of your transfer pricing position vis-à-vis rulings or ‘‘Advanced Pricing Agreements’’
  • A transfer pricing training workshop tailored to the needs of your staff,
  • etc.

A tip: Considering the new documentation requirements that will shortly come into effect, we recommend that you already start keeping records of all your transfer pricing transactions in a transfer pricing report. This report can be considered an insurance policy that your business concludes to substantiate its transfer pricing transactions and that it can use to optimise its tax position in a legally valid manner.

More about developments in international transfer pricing

Through the global consolidation of knowledge and regular consultation, we have acquired indispensable information and experience, and we monitor international transfer pricing developments daily. We would like to invite you to download Transfer Pricing News, our periodical newsletter.

Transfer pricing news

Transfer pricing audits: be prepared!

Guidance on Transfer Pricing implications of the COVID-19 pandemic published by the OECD

Publication of Belgian Transfer Pricing Circular

New Guidance on the Transfer Pricing of Financial Transactions – Time to act

Additional guidance on country-by-country reporting: summary of new questions and answers

Ruling Commission sets new deadline for prefilings on transfer pricing and innovation income deduction

Country-by-country reporting notifications: relaxation of legal requirements

New developments brought by the law on mechanisms for settling tax disputes in the European Union

Belgian tax authorities increase the number of Transfer Pricing audits drastically

Transfer Pricing requirements - due date 31 December 2018 postponed to 28 February 2019

Administrative penalties applicable in the event of failure to comply with the transfer pricing documentation obligations

Are you ready for a transfer pricing audit?

Approaching deadline for filing transfer pricing formalities and documentation

Law on transfer pricing documentation requirements in Belgium now published

Transfer pricing documentation forms published in the Belgian State Gazette

Transfer pricing documentation requirements in Belgium - Decision tree