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New Belgian accounting rules lead to transfer pricing documentation requirements ? |
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Belgian tax authorities in its administrative notices strongly recommend documenting transfer pricing (TP) policies between affiliated parties. However TP documentation as such is not stipulated in Belgian Tax Law itself.
A Royal Decree of August 10, 2009 (Royal Decree of August 10, 2009, Belgian Official Gazette, August 24, 2009, p.56386, mainly adjusting the Royal Decree of January 30, 2001 (general accounting principles in Belgium)) now obliges companies to provide in their statutory annual accounts in Belgium certain additional information on the nature and business purpose of their off-balance sheet arrangements, and on transactions with affiliated parties for which there is no proof that they are at arm’s length.
As described in the attached alert, these new accounting obligations could be interpreted as the implicit introduction of new transfer pricing documentation requirements. |
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15-09-2009 |
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