Ruling on profit attribution between Belgian headquarter and Mexican branch published
A recently published decision (No. 400.222) of the Belgian Ruling Committee of 24 March 2005 clarifies the profit attribution between a Belgian headquarter and its Mexican branch.
(a) Facts. A Belgian multinational group, which produces household and outdoor equipment, decided to establish a new production unit in Mexico. Accordingly, the Belgian headquarter company, NV A, would esta…
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