Establishing “arm’s length” conditions for intra-group transactions, better known as ”transfer pricing”, is a very hot topic for businesses whose activities expand beyond national borders. Moreover, when it comes to tax, entrepreneurs consider transfer pricing as one of their top priorities.
Last year a number of concrete initiatives were taken in the framework of the OECD’s “BEPS” action plan to combat (abnormal) profit shifting on an international level. As a result, the international fiscal landscape has been thoroughly reformed. The level of transparency expected from enterprises has never been as high. As a consequence, businesses with cross-border activities will have to cooperate with tax authorities in a more pro-active manner than before. However don’t be misled: transfer pricing is not limited to multinationals only! Belgian groups or start-ups with aspirations to expand their business across national borders will have to put an adequate transfer pricing policy in place too.
One of the cornerstones of the increased transparency are the new mandatory transfer pricing forms, of which a large part will need to be filed as an annex to the corporate income tax return (already in September 2017). Furthermore, similar transfer pricing rules have been enacted in other countries. While this transfer pricing documentation is an obligation for some, it is certainly an opportunity for everyone. Practice has shown that a thought-through and well-documented transfer pricing strategy can lead to tax optimization on group level.
During this info session we will provide you with some practical guidance with respect to setting up the most tax efficient distribution-, production- or license model. We’ll map out how your company can optimize intellectual property from a tax perspective. For instance, your company might fall within the scope of the new deduction for innovation income (Also be on the lookout for our separate seminar on innovation which will take place very soon!).
We will also get into more detail concerning the recent developments on permanent establishments. Due to less strict conditions than before, agents who are working abroad can give rise to a taxable presence more quickly.. The same applies to building sites and installation projects located in a foreign country. Hence, the importance for companies of applying an appropriate allocation of profit and losses is clearly on the rise.
The final topic which we will discuss concerns foreign withholding taxes which can be avoided or refunded in a lot of cases.
We are happy to invite you to our free info session which will be held in Brussels (in English), Hasselt and Herentals (both in Dutch).
Aanvang en tijdsduur12u00 tot 13u45
12u30 aanvang infosessie
13u45 einde en mogelijkheid tot informeel
SprekersJonas Derycke, Director Tax
Ben Veijfeijken, Senior Assistant Tax
Wouter Thijs, Senior Assistant Tax
Inschrijven tot 15/02/2017