Belgian entities of foreign- or Belgian-headquartered multinational groups with annual revenues exceeding 50 million euros need to start preparing their business for transfer pricing documentation obligations that will be introduced soon. Given the increased scrutiny, it’s also imperative to check the consistency of transfer pricing arrangements with actual conduct.
The OECD’s country-by-country reporting (CBCR). The threshold of 750 million euros consolidated revenues for completing and filing is expected to be maintained. It’s recommended to already start putting the necessary processes in place to collect and produce CBCR data and test whether systems are adequately equipped to handle or automate CBCR.
A Masterfile covering information relevant to the entire group of companies (subject to the aforementioned 50 million euros threshold)
A Local File and tax return form including detailed information about an individual entity’s inter-company transactions (subject to the aforementioned 50 million euros threshold).
While legislation still needs to be finalised, the Belgian Minister of Finance’s anti-fraud plan explicitly refers to the new obligations and it’s clear that the Masterfile and Local File obligations will be implemented as from financial year 2016, expanded with a tax return form obligation identifying intercompany transactions and counterparties.
Interpreting these obligations at a practical level can be extremely complex.
We’re fully versed on all aspects of the field and the impact the legislation will have on your organisation.
Our Belgian team of more than 50 full-time transfer pricing experts use proven documentation approach to helping clients comply with obligations in the most efficient manner.
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