Tax Insights | October 2022 | Transfer Pricing

Prefiling and ruling requests for transfer pricing and innovation deduction relating to financial year 2022 must be filed by 30 November 2022


The Ruling Commission announced on their website[1] a new deadline for submitting a prefiling request or a final ruling request (for files without a prefiling) regarding transfer pricing and innovation deduction for the financial year per 31 December 2022.

Prefilings and rulings must be filed at the latest on 30 November 2022 so that a decision can still be delivered before the deadline for filing the corporate income tax return (or non-resident corporate income tax).

In order to ensure a smooth processing of such a request for prefiling/ruling, the Ruling Commission asks to receive the documentation as soon as possible, including a description of the company, the activities performed, a justification regarding the requested transaction and a description of the method used with accompanying calculations.

Companies that do not close their accounts by calendar year are requested to submit the prefiling/ruling in a timely manner.  This means that the prefiling/ruling must be filed no later than eight months before the deadline for filing the corporate or non-resident income tax return.


Companies which want to have a confirmation that the used transfer pricing model or the innovation deduction for the financial year 2022, are acceptable for the Ruling Commission, need to take immediate action.     


If you have any questions regarding this topic, don’t hesitate to contact our RSM Belgium | Tax team (ta[email protected]).

RSM Belgium | Tax

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