The WTS newsletter summarizes new developments in the field of TP for 10 countries and has been prepared by local TP experts within the global WTS-network.

The Belgian tax authorities have granted an extension on the administrative deadline until 31 March 2018 regarding the filing of the Master file (275 MF), the Country-by-Country report (275 CBC) and Country-by-Country notification for 2018 (275 CBC NOT).

According to Dutch transfer pricing legislation (article 8b of the Dutch Corporate Income Tax Act), Dutch tax payers need to have documentation available that demonstrates the arm’s-length nature of transfer prices applied to intra-group transactions. This transfer pricing documentation should be part of a taxpayers’ administration.

Andy Neuteleers, Michiel Boeren and Jean-Luc Dascotte (Tiberghien) contributed to the WTS newsletter for October 2017 with an article on Luxembourg's new IP regime as of 2018.

We are happy to announce that T/A economics is mentioned as 'firm to watch' in the World Transfer Pricing 2018 rankings for all three Benelux countries.

As we reported earlier, Belgium has adopted formal transfer pricing documentation rules.

On 4 August, the Luxembourg Government submitted its long awaited bill of law for the introduction of a new tax regime in order to increase intellectual property (“IP”) developments (the “Bill of Law”). The new regime follows just over one year after the Luxembourg government abolished its former IP regime as from 30 June 2016 (subject to grandfathering rules in effect until no later than 30 June 2021). Once the bill of law is enacted, the new IP regime should become effective as of 2018.

In a Circular issued by the Cyprus Tax Authorities on 30 June 2017, new transfer pricing rules have been implemented for companies carrying out intra-group financing activities. The Circular is effective immediately and replace the former Minimum Margin Scheme regime. The Circular contains requirements regarding substance, risk/equity and arm’s length compensation.

The new rules for intra-group financing companies in Cyprus are largely similar to the rules implemented in Luxembourg at the beginning of this year. 

On July 10, 2017 the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Transfer Pricing Guidelines).

On June 22, 2017 the OECD released two public discussion drafts, containing guidance on its Final Reports on Base Erosion and Profit Shifting (BEPS) of October 2015. Both discussion drafts replace earlier draft versions released for public comment in July 2016.