In the week commencing 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. The questionnaire consists of around 30 questions, which reflects the tax authority’s use of two different information requests:
- A classic information request containing a list of 33 questions related to the company’s overall business, intra-group transactions, functions, risks, and assets.
- A new, short information request with a list of specific questions related to intra-group financing and withholding taxes.
Taxpayers are being allowed 30 days to reply, period may be extended upon request. Taxpayers may be allowed an opportunity to request a pre-audit meeting with tax authority if the taxpayer applies for the meeting within 10 days of receipt of the information request.
