Recent news

  1. Thursday, 11 April 2024

    2024 transfer pricing audit wave

    The Belgian tax authorities recently initiated the 2024 transfer pricing audit wave, starting with a questionnaire an a pre-audit meeting. 

  2. Wednesday, 21 February 2024

    Transfer pricing update France and Italy

    (France) Already in 2023, the French government stated that their new plan to combat tax- and customs (‘public finances’) fraud would introduce new measures to strengthen transfer pricing control/audits among taxpayers. These measures have now been introduced into law by the French Budget Bill 2024 and are applicable as of 1 January 2024.

    (Italy) A legislative decree published on 12 January 2024 has changed the deadline for filing the corporate income tax return for fiscal years starting after 31 December 2023. This change also has an impact on transfer pricing and the so-called penalty protection regime for preparing transfer pricing documentation.


  3. Friday, 13 October 2023

    BEFIT, towards a common corporate tax framework in the EU ?

    BEFIT stands for “Business in Europe: Framework for Income Taxation” and is the object of a draft EU directive proposed by the European Commission on 12 September 2023 (the “Draft Directive”). The stated aim of the Draft Directive is to reduce the tax compliance costs of large groups by proposing a unified and streamlined approach in the determination of the tax base of their EU companies.

  4. Thursday, 12 October 2023

    Breakfast seminar on transfer pricing

    Intercompany financial transactions have been high on company’s and tax authorities’ transfer pricing agendas for several years.

  5. Monday, 10 July 2023

    2022 annual report of the Belgian ruling commission

    The Belgian ruling commission published its annual report for 2022 on 12 June 2023. It can be consulted here in Dutch and French. A couple of notable decisions in relation to transfer pricing and the innovation income deduction are discussed below.

  6. Tuesday, 27 June 2023

    Brazil’ legislator enacts new transfer pricing law

    On 15 June 2023, Brazil published a new law establishing a transfer pricing framework that is aligned with the OECD Transfer Pricing Guidelines (“OECD TPG”). Reforming Brazil’s transfer pricing (“TP”) rules has been discussed for a long time but the debate was intensified since Brazil’s application to join the OECD in 2017 . The new law includes among others the introduction of the arm’s length principle and the implementation of the TP methods in accordance with the OECD TPG.

  7. Tuesday, 14 March 2023

    Silicon Valley Bank – Key Take-aways for Transfer Pricing

    With the Silicon Valley Bank (“SVB”) all over the financial news, in the below, we briefly summarize the case and provide you the key take-aways from a transfer pricing perspective on internal banks of multinational groups.

  8. Thursday, 12 January 2023

    Pillar Two/IFRS Newsflash: IASB consultation on IAS 12 amendements for Pillar Two

    On 9 January 2023, the International Accounting Standard Board (IASB) published Exposure Draft ED/2023/01 which contains important proposed amendments to IAS 12, the International Accounting Standard dealing with accounting for Income Taxes under IFRS. Any party interested may comment on this Exposure Draft by 10 March 2023.

  9. Wednesday, 30 November 2022

    The rise of the interest rate and the impact on valuations and transfer pricing

    Behold, the era of free money is no more. This might be hard to digest for governments, companies and investors alike. After an extensive period of record-low interest rates and the pandemic fading out in 2022, while economies worldwide are struggling to find their feet with supply chain issues, the war in Ukraine as well as with the comeback of inflation, the current rise of interest rates has several consequences. Further in this document, the impact of rising interest rates on valuations and transfer pricing is discussed in more detail. A key message is that it is better to take appropriate action instead of waiting on the sidelines.

  10. Monday, 14 November 2022

    Inflation – back for good?

    Is inflation back for good? A seemingly simple question, but apparently much harder to answer by politicians and central bankers alike. While the Fed is nervously trying to tame the inflation monster by increasing the key interest rates, the European Central Bank (“ECB”) initially was quite reluctant to do so (as its main concern was rather the national governments’ debt levels) and the false believe that the inflation hike was just a temporary issue. At first, the ECB commented that inflation was only fired up due to the higher energy prices as a reaction to the war in Ukraine. Now that the predicted inflation peak every month keeps on shifting to the next month, inflation looks much more persistent than initially anticipated (by ECB) with the latest Belgian inflation rates as per September 2022 well above 10%. According to the data below provided by the OECD, other countries are faced with similar percentages: