Services
Interim and TP/tax project management
As a growing business, you may have only a few people in your finance or tax team. There may be no or limited TP expertise "in-house". We can step in and be your interim project manager, developing, implementing and defending your transfer pricing policies. We can help you to manage large-scale international taxation projects with Big 4s or other service providers. In this role, we will be your "right hand" to choose and manage providers for different aspects of the project, assess the reasonability of proposals, budgets, and timelines, and follow up on the deliverables from content and timing perspectives.
TP Audits and controversy
We can help you to get ready for a transfer pricing audit by performing a TP compliance screening, preparing relevant documentation based on the OECD guidelines and international practice and assisting you with defining the company’s controversy strategy. We can support you with respect to ongoing TP inquiries (preparation of meetings, interactions with tax authorities, inquiry handling, etc.). We can also assist with appeals and litigation support, or with mutual agreement and arbitration procedures to obtain relief from double taxation following a TP adjustment.
Planning, business transformation and value drivers
Your business is constantly developing and evolving. The tax authorities have recently focused their attention to understanding the full supply chain of the taxpayers and the key elements that generate most of the value in their business. These are fundamental for establishing transfer pricing policies. We can help you to perform functional analysis and next, set up or modify the TP policies, followed up by their adequate documentation.
TP Compliance
Being compliant with TP documentation requirements is important from a penalty protection as well as from an audit readiness perspective. We can help you with the preparation of your Master file, Local files, CbC reports or local TP forms according to the OECD Guidelines. We can also help you to streamline and automatize the process by choosing and setting up (content-wise) one of the software tools available on the market. Such an approach will allow you to perform transfer pricing documentation "in-house" and spend minimum time on its annual updates. We can also assist with the assessment of DAC6 reporting requirements and with getting ready for the implementation of the OECD Two Pillar plan as well as other topics of international taxation.
Innovation Income Deduction or IID
In Belgium, companies may benefit from Innovation Income Deduction allowing to deduct up to 85% of their net innovation income from the tax base. We can assist you to determine whether your company's intellectual rights qualify for the regime and estimate the IID amount. This typically involves using a transfer pricing methodology supported by the adequate benchmarks. Further, we can also assist to prepare the recommended defense file or obtain a ruling from the Belgian tax authorities.
F.A.Q.
What kind of documentation can you create?
Do you use automation software for TP documentation?
Do you use automation software for TP documentation?
We can prepare a full range of transfer pricing documentation including Masterfile, Local files as well as Transactional Modules with appropriate benchmarks. The latter can be used as a part of the Local files as well as a separate planning or defense documentation for a particular transaction. We can also help you with preparation of th
We can prepare a full range of transfer pricing documentation including Masterfile, Local files as well as Transactional Modules with appropriate benchmarks. The latter can be used as a part of the Local files as well as a separate planning or defense documentation for a particular transaction. We can also help you with preparation of the intercompany agreements which are vital to have, as well as the supporting background materials that are increasingly requested by tax authorities (i.e. interviews documenting business functions and value drivers, analyses of key personnel, industry analyses, etc.)
Do you use automation software for TP documentation?
Do you use automation software for TP documentation?
Do you use automation software for TP documentation?
We can assist you with automation of your transfer pricing documentation. This work includes preparation of the Transactional Modules documenting the functional and risk analysis of the parties and other comparability aspects of analysis. We can help you to select the most appropriate automation tool amongst available on the market based
We can assist you with automation of your transfer pricing documentation. This work includes preparation of the Transactional Modules documenting the functional and risk analysis of the parties and other comparability aspects of analysis. We can help you to select the most appropriate automation tool amongst available on the market based on your criteria and budget, as well as to set it up using the prepared Transactional Modules and to populate the rest of necessary information.
Do you perform benchmarking / comparable searches?
Do you use automation software for TP documentation?
What about a sign-off on the opinion or a TP analysis in another country?
Yes, we do! We perform and consult on the searches for royalties, service fees and comparable companies. We also work with our well-established partners for the comparable companies searches and financial transactions benchmarks. We ensure that the searches comply with the standards and practices of Belgium and relevant country(ies). We
Yes, we do! We perform and consult on the searches for royalties, service fees and comparable companies. We also work with our well-established partners for the comparable companies searches and financial transactions benchmarks. We ensure that the searches comply with the standards and practices of Belgium and relevant country(ies). We will carefully explain the performed search to you and ensure that it fits best in the Group's TP policy and documentation.
What about a sign-off on the opinion or a TP analysis in another country?
I am a financial / legal adviser or accountant and my client has a transfer pricing question. Can you help?
What about a sign-off on the opinion or a TP analysis in another country?
Transfer pricing always implies more than one country, hence one needs to evaluate the analysis from more than one perspective. We have developed a network of experienced and trustworthy contacts in various jurisdiction that we can recommend for a review from the perspectives of jurisdiction other than Belgium.
I am a financial / legal adviser or accountant and my client has a transfer pricing question. Can you help?
I am a financial / legal adviser or accountant and my client has a transfer pricing question. Can you help?
I am a financial / legal adviser or accountant and my client has a transfer pricing question. Can you help?
Yes, we can. Together with you, we will discuss the scope and the issue and will suggest the best and most pragmatic approach to assist your client.