Belgium Ramps Up Transfer Pricing Audit Process

June 20, 2018

Belgium Ramps Up Transfer Pricing Audit Process

~1-minute read. This article is part of our CrossBorder Audit Alert series.

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Belgium Increases Staff for Audit Process

 

In 2018, the Belgian transfer pricing investigation team (TP Unit) began a wave of several hundred transfer pricing investigations. The TP Unit is expected to have a 40% increase of staff members as the year progresses to carry out those audits.

The TP Unit has also enhanced its cooperation with the Large Company Department and has trained over 200 field agents on transfer pricing audit techniques.

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In an attempt to raise revenue and lower the budget deficit, HM Revenue and Customs announced that that between 2011-2016, HMRC secured 5.9 billion of additional tax by challenging the transfer pricing arrangements of multinational corporations! The total amount secured in 2016/17 was 1.6B which was a 50% increase over the amount collected in 2015/16.

Similarly, the Diverted Profit Tax, which is designed to encourage large companies to comply with international tax rules including transfer pricing, raised 281M in 2016/17. This was a 90% increase from 2015/2016.

To collect this amount, the HMRC has 82 full time staff in its specialist transfer pricing group. This number is expected to increase dramatically.

CrossBorder Solutions predicts that this upward trend will continue and MNC taxpayers should expect transfer pricing audits and adjustments to increase dramatically.

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