Assistance in TP Audits

Assistance in TP Audits

Adjustments made in 2012 by the special transfer pricing audit department of the Belgian tax authorities amounted to EUR 275 million.

Adjustments made in 2012 by the special transfer pricing audit department of the...

Adjustments made in 2012 by the special transfer pricing audit department of the Belgian tax authorities amounted to EUR 275 million. Given the current budgetary needs of the Belgian government, the ongoing developments at the level of the OECD (such as the country-by-county reporting) and the EU, the audit activity of the special transfer pricing audit department will most likely not stop there and increase over the next years.

How KPMG can help

Operational since 2004, they have grown to become a well-oiled machine whose expertise now matches those of specialized tax advisers. They are not afraid to go meet with foreign tax authorities to justify adjustments performed in Belgium in the framework of double taxation avoidance procedures (such as the mutual agreement procedure foreseen by article 25 of the OECD Model Tax Convention and the European Arbitration Convention).

Multinationals increasingly risk transfer pricing audits. They can be costly, and an unfavorable outcome can lead to tax adjustments, penalties, and interest charges. Transfer Pricing enquiries can be time-consuming and involve a commitment of resources in assembling paperwork, preparing responses to detailed inquiries, and corresponding and negotiating with tax authorities.

We can assist you in determining an effective strategy for responding to such challenges, provide robust economic analysis in support of your existing transfer prices, help you prepare strong responses to detailed inquiries, and support you in negotiations with tax authorities.

Where a tax adjustment leads to international double taxation, we can assist you in the national and international procedures (such as the mutual agreement procedure or arbitrage procedure) to claim double taxation avoidance with the relevant tax authorities.

KPMG’s transfer pricing practice has significant experience in responding and challenging the issues raised by tax authorities.

Why KPMG?

Our team of dispute resolution professionals includes:

  • Former tax-authority officers with detailed knowledge and experience regarding the approaches taken by tax authorities
  • Tax professionals with a sound grasp of local legislation, including statutory limitations on tax authorities to request information, and experience with tax audits
  • Economists who analyze the arm’s length nature of the transfer prices in question

 

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