On 19 February 2025, the OECD released the report on Amount B of Pillar One, providing a Simplified and Streamlined (S&S) approach to determine an arm’s length remuneration for baseline marketing and distribution activities. This standardized methodology eliminates the need for a benchmark and establishes a fixed return on sales ranging from 1.5% to 5.5%.

As announced during the technical webinar held on 11 February 2025 by the Organisation for Economic Cooperation and Development (OECD) , a consolidated report has been released on Amount B incorporating the agreed materials on Amount B that have been released by the Inclusive Framework from February 2024 until December 2024. A newsflash summarizing the key highlights will follow.

We are pleased to share that Tiberghien has been ranked as a Leading Firm in the Leaders League rankings for 2025.

On September 11 & 12, transfer pricing professionals from varying industries as well as international tax lawyers will gather in Amsterdam for the 2024 ITR World Transfer Pricing Forum.

Kenny Van Tulder is scheduled as a speaker on Wednesday at 11h15 and will be sharing his valuable insights during the Global transfer pricing update: Geographic Roundtables - EMEA, Americas, APAC. 

Feel free to learn more about the event, the agenda and how to register on following website. 

We are pleased to share that Tiberghien has been ranked as a Top Tier Firm in the ITR World Tax rankings for 2025. We are particularly proud to be Tier 2 for Transfer Pricing and would like to thank our clients, for their positive feedback and trusting us with their transfer pricing matters! For more information on these rankings, click here

The Royal Decree of 16 June 2024, published in the Belgian Official Gazette on 15 July 2024, introduces modifications to the transfer pricing forms 275.MF, 275.LF and 275.CBC NOT. This royal decree replaces the royalty decree of 28 October 2016 and will be applicable for financial years starting on or after 1 January, 2025.

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

(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.

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.

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