Transfer pricing implies that all transactions between related companies must be on arm’s length terms<\/strong>. Thus, the prices charged to a group company must be similar to the prices an independent party would pay in similar circumstances.<\/p>\nAll intra-group transactions must follow this general principle, both when providing goods or services and when paying interest to a group company. If a tax audit reveals that the prices or conditions charged are not in line with market conditions, corrections may be imposed, possibly resulting in double economic taxation. In practice, obtaining relief for this is often a long and difficult process.<\/p>\n
Large companies are also subject to an obligation to prepare transfer pricing documentation, which consists of a Master File and a Local File. Corporate groups with consolidated group revenue of at least \u20ac750 million must also file a Country-by-Country Report.<\/p>\n<\/div><\/div><\/div><\/div><\/div>
Our services<\/h2><\/div><\/div><\/div>Analysis and strategy<\/h3><\/div>We will guide you in the following matters:<\/p>\n
\n- Functional analysis of the group structure and determine optimal transfer pricing structure (transfer pricing modeling).<\/li>\n
- Defining transfer pricing methodology and transfer pricing benchmarking.<\/li>\n
- Preparation of transfer pricing policies, documents and contracts.<\/li>\n
- Preparation and submission of mandatory documentation such as Master File, Local File, Country-by-Country Report or CbC-not.<\/li>\n
- Restructuring the group structure in line with transfer pricing model in a tax optimal manner.<\/li>\n<\/ul>\n<\/div><\/div><\/div>
Formal reporting<\/h3><\/div>When certain thresholds in turnover, balance sheet total or number of employees are exceeded, a Belgian company that is part of an international group must prepare specific TP reporting.<\/p>\n
Our experts assist you in the preparation and submission of the following reports, among others:<\/p>\n
\n- Local File and Master File<\/li>\n
- Country-by-Country Report<\/li>\n
- Country-by-Country Notification<\/li>\n<\/ul>\n<\/div><\/div><\/div><\/div><\/div><\/div><\/div><\/div>
Frequently asked questions about transfer pricing<\/h2><\/div>