Yesterday, the Belgian tax administration published the Circular Letter “Transfer Pricing” (Circular Letter 2020/C/35). This document is the final version of the Circular Letter following the draft Circular Letter that was initially published on 9 November 2018, to which stakeholders were invited to submit comments (in two rounds, respective deadlines of December 2018 and June 2019).

The Inclusive Framework on BEPS (“IF”) members strongly support reaching a multilateral agreement with respect to Pillar One and Pillar Two as well as recognizing the concurrent work, on a without prejudice basis, on the two pillars. As a result, these members affirm their commitment to reach an agreement on a consensus-based solution by the end of 2020. In light of the above, the IF published a statement based on technical work provided by the Working Parties, as well as comments from the public consultation round and discussions at a number of Steering Group meetings. The IF has agreed upon an outline of the architecture of a Unified Approach on Pillar One which will serve as a basis for negotiations. Additionally, it welcomed the progress made on Pillar Two. This statement can be found at http://bit.ly/2S9WrZh

On 9 October 2019, the OECD published a proposal for a “unified approach” to the nexus and profit allocation challenges arising from the digital economy.

The EU General Court Tuesday ruled in favor of Starbucks and in disadvantage of Fiat on the European’s Commission claim that both companies received illegal state aid from the Dutch, respectively Luxembourg tax administration. Notwithstanding the general expectation exists that both cases will be further dealt with in appeal, they will be intensively analyzed, in particular by Apple whose case is still under examination.

26-27 September 2019 | 8.45 a.m. - 3.50 p.m. | NH Grand Hotel Krasnapolsky Amsterdam

De Belgische belastingadministratie deed op 9 november jl. een oproep om commentaren te voorzien op de door hun opgestelde ontwerpcirculaire ‘verrekenprijzen’.

The WTS Global 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.

On July 3, 2018 the OECD released the highly anticipated discussion draft on financial transactions, which deals with the follow-up work in relation to Actions 8-10 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Public comments are invited on the discussion draft and should be submitted by September 7, 2018.

Due to the introduction of the mandatory transfer pricing documentation in Belgium in 2016, the filing date for the local file form (form 275 LF) for a large amount of Belgian entities that form part of a multinational group is approaching for the second time.