How can the new ruling system be applied to a shared service center or a distribution center?
The transfer price of a shared service center/distribution center can be ruled off on a cost-plus base. Depending on the facts and circumstances, certain costs such as disbursements can be excluded from this cost-plus base. In addition, rulings could be applied in other areas such as Customs and VAT. For example: • Ruling on the exclusion of certain costs from the customs value of imported goods e.g. • Royalty payments; • Buying commissions; • Late payment interest; • Rulings on Binding Tariff Information (BTI) and/or Binding Origin Information (BOI), which give certainty to importers concerning the classification of goods and the possible use of preferential tariff rates. – Further application of the Ruling The new Belgian ruling system can be used to develop – with legal certainty – new business strategies which may offer substantial advantages compared to those previously offered by, for example, informal capital rulings or even coordination centers. The new ruling system operates o