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Belgium Publishes Decree on Transfer Pricing Documentation Penalties

|Approved Changes|Belgium
Belgium

On 2 August 2018, the Belgian Ministry of Finance published the Royal Decree of 29 June 2018 on administrative penalties for taxpayers that fail to comply with their transfer pricing documentation obligations. The penalties are as follows:

  • An offense due to circumstances beyond the taxpayer's control: No penalty
  • An offense that is not attributable to bad faith or intent to evaded tax:
    • First offense – No penalty
    • Second offense – EUR 1,250
    • Third offense – EUR 6,250
    • Fourth offense – EUR 12,500

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