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Unilateral Advance Pricing Agreement

Unilateral Advance Pricing Agreement Template for Belgium

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Key Requirements PROMPT example:

Unilateral Advance Pricing Agreement

"I need a Unilateral Advance Pricing Agreement for my Belgian pharmaceutical company's IP licensing transactions with our Swiss subsidiary, to be effective from March 2025, with particular focus on royalty payments and R&D cost-sharing arrangements."

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Document background
The Unilateral Advance Pricing Agreement is a crucial instrument in Belgian tax practice for companies seeking certainty in their transfer pricing arrangements. It is particularly valuable for multinational enterprises with significant intercompany transactions who wish to minimize transfer pricing risks and avoid potential disputes with tax authorities. The document is founded on Article 185 of the Belgian Income Tax Code and is administered by the Service des Décisions Anticipées. It provides taxpayers with binding confirmation of their transfer pricing methodology's acceptability for a specified future period, typically covering specific transactions, products, or services. The agreement includes detailed technical analysis, critical assumptions, and annual compliance requirements, all aligned with both Belgian tax law and OECD Transfer Pricing Guidelines.
Suggested Sections

1. Parties: Identification of the taxpayer and the Belgian Tax Administration (Service des Décisions Anticipées)

2. Background: Context of the application, including brief description of the company's operations and reason for seeking the APA

3. Definitions: Key terms used throughout the agreement, including technical transfer pricing terminology

4. Scope of the Agreement: Specific transactions, products, or services covered by the APA

5. Term of Agreement: Duration of the APA, typically 3-5 years, including effective date and expiration date

6. Transfer Pricing Methodology: Detailed description of the agreed transfer pricing method and how it will be applied

7. Critical Assumptions: Fundamental assumptions underlying the APA that, if changed, could affect its validity

8. Annual Compliance Requirements: Reporting obligations and documentation requirements to demonstrate compliance

9. Revision and Cancellation: Circumstances under which the APA may be revised or terminated

10. Confidentiality: Provisions regarding the confidential treatment of information exchanged

11. Execution: Signature blocks and formal approval statements

Optional Sections

1. Compensating Adjustments: Procedures for making year-end adjustments to ensure compliance with the agreed methodology, included when specific adjustment mechanisms are needed

2. Dispute Resolution: Procedures for resolving disagreements about the implementation of the APA, included when specific dispute resolution mechanisms are desired

3. Renewal Provisions: Terms and procedures for extending the APA beyond its initial term, included when longer-term certainty is sought

4. Force Majeure: Provisions for handling extraordinary circumstances that might affect the application of the APA, included when operating in volatile markets or conditions

5. Language: Specification of official language(s) of the agreement, included when multiple languages are involved

Suggested Schedules

1. Schedule A - Covered Transactions: Detailed description of all intercompany transactions covered by the APA

2. Schedule B - Transfer Pricing Methodology Details: Technical details of the approved methodology, including calculations and examples

3. Schedule C - Critical Assumptions Details: Comprehensive list and explanation of all critical assumptions

4. Schedule D - Annual Reporting Template: Format and content requirements for annual compliance reports

5. Schedule E - Financial Data: Historical financial data and projections supporting the transfer pricing methodology

6. Appendix 1 - Organizational Structure: Group structure chart and description of relevant related entities

7. Appendix 2 - Functional Analysis: Detailed analysis of functions, assets, and risks of the parties involved in covered transactions

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Agreement
Arm's Length Principle
Arm's Length Range
Associated Enterprises
Belgian Tax Administration
Compensating Adjustment
Comparable Uncontrolled Price
Controlled Transaction
Cost Plus Method
Critical Assumptions
Effective Date
Financial Statements
Fiscal Year
Foreign Associated Enterprise
Functions, Assets and Risks
Group
Independent Comparables
Intercompany Transaction
Operating Margin
Parent Company
Party/Parties
Profit Level Indicator
Related Party
Resale Price Method
Review Period
Ruling Commission
Service des Décisions Anticipées
Subsidiary
Tax Year
Term
Testing Party
Transfer Pricing Method
Transfer Pricing Documentation
Transactional Net Margin Method
Working Day
Relevant Industries

Manufacturing

Pharmaceutical

Technology

Financial Services

Automotive

Consumer Goods

Energy

Telecommunications

Professional Services

Chemical Industry

Relevant Teams

Tax

Finance

Legal

Treasury

International Operations

Compliance

Transfer Pricing

Corporate Development

Financial Planning & Analysis

Risk Management

Relevant Roles

Tax Director

Chief Financial Officer

Transfer Pricing Manager

International Tax Manager

Tax Counsel

Financial Controller

Head of Tax

Treasury Manager

Finance Director

Tax Planning Manager

Compliance Officer

Group Financial Controller

Industries
Belgian Income Tax Code (Article 185): Primary legislation establishing the arm's length principle in Belgian tax law and providing the legal basis for transfer pricing adjustments
Law of 24 December 2002: Establishes the Belgian Ruling Commission (Service des Décisions Anticipées/Dienst Voorafgaande Beslissingen) which handles APA requests
Belgian Transfer Pricing Circular Letter (2020): Administrative guidance on transfer pricing methods and documentation requirements in Belgium
OECD Transfer Pricing Guidelines: International guidelines followed by Belgian tax authorities in evaluating transfer pricing arrangements
Royal Decree of 30 January 2003: Implements the practical aspects of the ruling system, including procedural requirements for APA applications
Belgian Program Law of 1 July 2016: Contains specific transfer pricing documentation requirements including Local File and Master File obligations
Article 26 of the Belgian Income Tax Code: Provides authority for tax adjustments related to abnormal or gratuitous advantages granted by Belgian enterprises
Belgian Administrative Guidelines on APAs: Detailed procedural guidance on how to file and process APA requests, including required documentation and timeframes
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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