Our transfer pricing expert team can help you in deciding on an appropriate transfer pricing policy for cross-border intragroup transactions. In doing so, we document at arm’s length profit margins, amongst others for manufacturing entities, low-risk distributors, foreign branches, set up in Belgium or abroad. We align your transfer pricing policy with your business goals, whilst taking into account international tax planning opportunities.
We can help you with the following:
- Designing cost-efficient and tax-friendly transfer pricing business models;
- Minimising the risk of international double taxation;
- Securing transfer pricing policies by obtaining advance tax rulings;
- Drafting or reviewing transfer pricing documentation, in line with the revised July 2017 OECD Guidelines and ‘BEPS’ Action Plan, in particular Local & Master File requirements as well as country-by-country reporting;
- Conducting benchmark database studies in order to document the arm’s length range;
- Intellectual property planning, for instance implementation of the Belgian patent income deduction or R&D innovative tax deduction;
- Identifying international tax planning opportunities (withholding tax mitigation, thin cap issues, holding structures, etc.);
- Tax audit assistance.
Van Havermaet International is an alliance partner of Quantera Global. Quantera Global is the world’s leading independent transfer pricing advisory firm, providing specialist transfer pricing services to multinationals of all sizes across the globe. Quantera Global has offices across Europe and Asia. Its alliance partners are spread across the globe such that Quantera Global and its partners can provide a lean, multi-jurisdiction service without the complications and extra cost of the global accounting networks or law firms.
AUDIT OF YOUR TRANSFER PRICING IN 2021: IS YOUR COMPANY READY?
A new year also means new transfer pricing audits. As a result of the new transfer pricing documentation requirements introduced in 2016, transfer pricing is high on the priority list of the Belgian tax administration. Therefore, over the last few years, the administration has focused on expanding the transfer pricing cell, as well as strengthening the administration of the Special Tax Inspectorate (“STI”) with the necessary transfer pricing knowledge. In practice, this has manifested itself in a sharp increase in the number of transfer pricing audits.
Transfer pricing in 2019: time for action?!
TP documentation filing deadline is approaching!
As of 2016, transfer pricing documentation obligations have been introduced in Belgium. Hence, as in many other countries, Belgian entities have to draw up and submit transfer pricing documentation when certain criteria are met. See also our previous newsletter for more information. This means, for example, that qualified Belgian entities, which are part of a multinational group, are obliged to prepare and electronically submit both a Master file and a Local File.
Deadline approaching for electronic filing of Belgian transfer pricing ‘BEPS13’ forms (Master File – Country-by-country reporting)
Qualifying Belgian group entities which are member of an international group should take into account the upcoming deadline of 31st December 2018 for electronic filing of the Belgian Master File form ‘275MF’ as well as the Country-by-country reporting (275 CBC NOT and/or 275 CBC).