Belgium Court of Appeal Holds Transfer Pricing Guidelines on DEMPE Functions May Not be Applied Retroactively

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…
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