Struggling with transfer pricing investigations?
The 2019 TP audit wave has arrived, and as expected, the 2019 standard TP audit questionnaire is similar compared to last year’s edition.
Even though not much has changed in the TP audit questionnaire, Deloitte still expects this year’s audit wave to be unique and have a greater impact on taxpayers, for the following reasons, among others:
- The TP audit team of the Belgian Tax authorities (“TP auditors”) will join forces with the regional tax inspectors of the 7 centres “Grandes Entreprises / Grote Ondernemingen”. Practically, the TP auditors will provide technical support on any transfer pricing issue spotted during traditional corporate tax audits which could lead to in-depth TP audit.
- An overall increase in experience of TP auditors (i.e. lessons learnt from the past and intensive in-house training sessions on transfer pricing matters).
- An increase in scrutiny on certain risk indicators, such as volatile sales or profit margins, structural loss-making position, significant carry forward tax losses, high debt-equity ratios or business restructurings announced in the media.
- More burdensome TP documentation requirements (i.e. local form, master form, CbC reporting), while the taxpayer needs to ensure consistency across all TP reporting.