Transfer Pricing: administrative fines published

Violations

With the publication of the Royal Decree, these administrative fines have now also entered into force. The application rules and the scales of the administrative fines regarding the failure to correctly comply with the documentation obligations for transfer pricing are clarified in the Royal Decree. Possible violations include the non-submission or late submission of documents, the submission of incomplete or incorrect documents and intentional tax evasion.

Possible administrative fines

If the master file, the local file or the country report is not submitted or is submitted late or is incomplete, the tax authorities can impose a fine of between 1,250 euros and 25,000 euros on the Belgian group entity. However, if the tax authorities attribute the violations to malicious intent to evade tax, a fine of 12,500 euros can be imposed for the first offence. A fine of 25,000 euros can be imposed each time from the second violation.

Do you have any questions about transfer pricing? Please feel free to contact one of our specialists via contact@vdl.be.