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.

On 27 December 2016, the Luxembourg Tax Authorities ("LTA") issued new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 ("the Circular") dealing with the Luxembourg tax treatment applicable to Luxembourg companies engaged in intra-group financing transactions.

T/A economics' partner WTS was distinguished in two areas at this year’s International Tax Review (ITR) European Awards Ceremony, which took place on May 18 in London. WTS Global was honored with the award for European Indirect Tax Firm of the Year 2017 and WTS Germany was crowned Germany‘s Tax Firm of the Year 2017.

On April 6th, the Organization for Economic Cooperation and Development (OECD) launched additional guidance for tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) reporting (BEPS Action 13).