A significant number of taxpayers report having received requests for information (in a slightly updated format) concerning their transfer pricing transactions, and it is anticipated that, in the coming months, many more taxpayers will receive such inquiries.
Increased activities of the special transfer pricing audit department
A special transfer pricing audit department was formally established in 2006 (it actually had been functioning since late 2004).
Statistics reveal that in 2007, the department’s transfer pricing investigations resulted in €12 million of additional taxes being collected. In 2011, the amount of additional taxes from transfer pricing investigations increased to €67 million.
Business restructuring issues are reported to be subject to increased attention from the special transfer pricing audit department.
Furthermore, given the continuing need for revenue for the Belgian government, it is anticipated that the number of transfer pricing audits will significantly increase beginning in 2013 onwards.
The increased focus on transfer pricing matters and the rising number of transfer pricing audits is supported by the large number of companies in Belgium that received a rather lengthy standard transfer pricing questionnaire in January 2013.
Read a January 2013 report prepared by the KPMG member firm in Belgium: Increased transfer pricing audit activity noticed since early January 2013
Contact a tax professional with KPMG's Global Transfer Pricing Services.