According to recent reports, the Ghent Court of Appeal in Belgium issued a decision in June 2021 concerning whether the 2017 OECD Transfer Pricing Guidelines may be applied on a retroactive basis. The case involved a transfer pricing dispute in relation to royalty income for the licensing of intangible assets by a non-resident related party of a Belgian taxpayer in the 2009 fiscal year. Relying on the 2017 guidelines, the Belgian tax administration determined that the Belgian taxpayer had car…