On 8 February 2019, the Belgian Federal Public Service (SPF) Finance published Circular Letter No. 2019/C/14, which clarifies the application of penalties for failing to fulfill transfer pricing reporting obligations, including in respect of changes introduced by the Royal Decree of 29 June 2018. This includes three penalty tiers depending on the nature of the offense:
- Type A - an offense due to circumstances beyond the taxpayer's control, in which case no penalty applies;
- Type B - an offen…