Headline Verdana Bold Operationalizing Transfer Pricing From Theory to Practice Deloitte Belgium, 16 May 2017

Transcription

1 Headline Verdana Bold Operationalizing Transfer Pricing From Theory to Practice Deloitte Belgium, 16 May 2017

2 Operationalizing Transfer Pricing From Theory to Practice Agenda Topic Content Presenters Timing Introduction Concepts & Framework Thierry Chaumantin 3:00 p.m. 3:15 p.m. Session 1: Implementing a TP Policy Manage E2E Cycle Structure operations Jeroen Lemmens 3:15 p.m. 4:00 p.m. Session 2: Addressing Common Challenges Indirect Tax Management Reporting Liesbet Nevelsteen Thierry Chaumantin 4:00 p.m. 4:40 p.m. System Data Gaps Coffee Break (20 min) Session 3: Case study: Applying Technology to manage E2E Process for Transfer Pricing on Goods Scenario Tool Demo Thierry Chaumantin Delphine Maeckelberghe 5:00 p.m. 5:50 p.m. Conclusion Key Messages Next Steps Jeroen Lemmens Liesbet Nevelsteen 5:50 p.m p.m. Reception 2017 Deloitte Belgium 2

3 Introduction 2017 Deloitte Belgium 3

4 Transfer Pricing Some Concepts often misunderstood by Business Finance Teams Arm s Length Mark-up True-up VAT Man 2017 Deloitte Belgium 4

5 Operationalizing Transfer Pricing The Building Blocks 1. Manage E2E TP life cycle 2. Structure TP operations 3. Address common challenges Business model Defend Planning / Ex-ante documentation People & Organization Indirect Tax (Ex-post) Documentation TP Life Cycle TP procedures Policy & Process Management Reporting Control Calculate Data & Technology System Data Gaps Plan Process Operate Defend 2017 Deloitte Belgium 5

6 Traditional Transfer Pricing Documentation Focused I/C flow TP tax audit Defend Business model Planning / Ex-ante documentation TP policy TP benchmarks I/C agreement TP local file TP master file CbCR (Ex-post) Documentation TP Life Cycle TP procedures Guidelines Operating procedure Others Plan Black boxes Defend 2017 Deloitte Belgium 6

7 Operationalized Transfer Pricing Manage the Numbers: Calculate, Process & Control Business model Defend Planning / Ex-ante documentation (Ex-post) Documentation TP Life Cycle TP procedures Plan Control Process Calculate Specific know how required Operate Defend 2017 Deloitte Belgium 7

8 Session 1 Implementing a TP Policy Manage E2E TP Cycle & structure Operations 2017 Deloitte Belgium 8

9 Implementing a TP Policy Manage the E2E TP Life Cycle 1. Manage E2E TP life cycle 2. Structure TP operations 3. Address common challenges Business model Defend Planning / Ex-ante documentation People & Organization Indirect Tax (Ex-post) Documentation TP Life Cycle TP procedures Policy & Process Management Reporting Control Calculate Data & Technology System Data Gaps Plan Process Operate Defend 2017 Deloitte Belgium 9

10 Manage the TP Life Cycle Plan Phase Check List Defend Business model Planning / Ex-ante documentation TP Manager I/C flows classification I/C agreements Valid TP benchmarks Actionable TP procedures Procedure to identify change in business model (Ex-post) Documentation TP Life Cycle TP procedures Control Calculate Plan Operate Defend Process 2017 Deloitte Belgium 10

11 Manage the TP Life Cycle Defend Phase Check List TP Manager Ex-post documentation available Alignment between expost and ex-ante documentation Consistency between expost documentation of different countries Defend Business model Planning / Ex-ante documentation (Ex-post) Documentation TP Life Cycle TP procedures Control Calculate Plan Process Operate Defend 2017 Deloitte Belgium 11

12 TP Life Cycle Operate Phase Check List Business model TP Manager Defend Planning / Ex-ante documentation (Ex-post) Documentation TP Life Cycle TP procedures Control Plan Operate Defend Process Calculate Effective tools to calculate TP on goods Effective tools to calculate TP on services Adequate I/C invoice process Approach to handle I/C price correction 2017 Deloitte Belgium 12

13 TP Life Cycle Preliminary Assessment Poll Survey 1 I have a very accurate overview of all material intercompany flows in my supply chain. 2 There are effective internal procedures in place to rapidly detect any new intercompany flow that occurs during the fiscal year. 3 Each material intercompany flow can be easily referenced back to an up-to-date and valid TP Benchmark study (i.e. accepted during a tax audit). 4 Each material intercompany flow can be easily referenced back to an up-to-date and valid intercompany agreement (i.e. accepted during a tax audit). 5 For each material intercompany flow, there is an effective internal procedure to check whether the activities performed by the related parties as described in the intercompany agreement match the ones used to perform the TP Benchmark study. 6 There is an annual review process to check whether existing intercompany agreements are still consistent with the way the supply chain operates. There is a TP policy that describes how the transfer prices need to be calculated for each intercompany transaction in order to meet arm s length principles 7 requirements. 8 If it exists, the TP policy is rigorously followed in practice. More specifically, the setting of transfer prices is never the outcome of internal negotiations between the managers of the related parties. 9 The way the transfer prices on tangible goods are set up do not have any impact on the performance bonuses of the local sales teams and/or manufacturing teams; more specifically, for the employees of a legal entity with a routine margin function (i.e. limited risk distributor, contract manufacturer). 10 There is an annual review process to check whether the TP policy is consistent with the way the supply chain operates. 11 The budget numbers are used to calculate transfer prices on tangible goods that need to be applied for the next fiscal year There is a process to regularly calculate the correct transfer prices on tangible goods based on YTD actuals and the forecasts for the remainder of the year. These recalculated transfer prices are subsequently updated in the ERP. For legal entities with several functions (e.g. distribution and manufacturing), there is an easy mechanism to segment the entity EBIT by function so that the actual profit margin each function can be monitored separately. 14 Actual YTD EBIT segmented by function can easily be obtained on a quarterly basis both in management GAAP (IFRS) and in local GAAP. 15 Pro-active updates of transfer prices are regularly performed during the fiscal year to avoid large year-end TP true-up adjustments. 16 The allocation keys used for calculating intercompany recharge of services are well documented. 17 The types of evidence needed to substantiate whether a given intercompany service has been actually performed, have been defined. The related supporting documentation is archived so that it can be easily retrieved during a tax audit. 18 There is a well-defined procedure to identify which cost components are to be included or excluded (shareholder costs) from the cost base of intercompany service recharges. 19 The VAT treatment of all intercompany invoices (goods, services) has been reviewed and signed-off by the Indirect Tax team The Indirect Tax impact (customs and VAT) of TP true-up invoices has been evaluated and potential negative consequences (e.g. custom fees & duties exposure, Intrastat reporting) are mitigated. The way TP true-ups are implemented (credit note/debit note vs marketing fees allocation) between related parties is consistent with the roles & responsibilities described in the related intercompany agreement. 22 The VAT treatment and VAT compliance of TP true-up invoices have been reviewed and signed off by the Indirect Tax team. 23 The way TP true-ups are booked, does not affect the business units Management Reporting (i.e. TP true-ups are always booked below the line ) The financial reports required for local TP documentation (e.g. EBIT segmented by function, amount of intercompany sales & purchases by transaction type and counterpart) can be easily produced from my company s ERP/financial systems. There is an annual review process to check whether the financial data included in the local TP documentation is consistent with the TP Benchmark studies and the TP policy Deloitte Belgium 13

14 TP Life Cycle Preliminary Assessment result Plan Business model Percentage of those who think that there are no effective internal procedures in place to rapidly detect any new intercompany flow that occurs during the fiscal year. 61% Ex-ante documentation TP procedures 78% Percentage of those who think that it is not easy to reference back the material intercompany flow to an up-to-date and valid TP Benchmark study (i.e. accepted during a tax audit). Percentage of those who think there is no proper annual review process to check whether the TP policy is consistent with the way the supply chain operates. 74% 2017 Deloitte Belgium 14

15 TP Life Cycle Preliminary Assessment result Operate Calculate Percentage of those who are not sure whether that the transfer prices on tangible goods for the next fiscal year are based on the budget numbers. 61% Process 50% Percentage of those who think that the Indirect Tax impact of TP true-up invoices has not been evaluated, nor that the potential negative consequences (e.g. custom fees & duties exposure, Intrastat reporting) are being mitigated. Control Percentage of those who find it difficult to obtain the actual YTD EBIT segmented by function on a quarterly basis both in management GAAP (IFRS) and in local GAAP. 83% 2017 Deloitte Belgium 15

16 TP Life Cycle Preliminary Assessment result Defend (Ex-post) Documentation Percentage of those who do not think that the financial reports required for local TP documentation can be easily produced. 78% 56% (Ex-post) Documentation Percentage of those who are not sure that there is an annual review process to check whether the financial data included in the local TP documentation is consistent with the TP Benchmark studies and the TP policy Deloitte Belgium 16

17 Implementing a TP Policy Structure TP Operations 1. Manage E2E TP life cycle 2. Structure TP operations 3. Address common challenges Business model Defend Planning / Ex-ante documentation People & Organization Indirect Tax (Ex-post) Documentation TP Life Cycle TP procedures Policy & Process Management Reporting Control Calculate Data & Technology System Data Gaps Plan Process Operate Defend 2017 Deloitte Belgium 17

18 TP Governance Identify Gaps in Roles & Responsibilities (Illustration) People & Organization Policy & Process Data & Technology Ex-ante documentation TP procedures Calculate Process Control Ex-post documentation TP Manager FP&A Finance IT SSC Indirect Tax 2017 Deloitte Belgium 18

19 TP Procedures From generic TP Guidelines to Standard Operating Procedures (SOPs) People & Organization Policy & Process Data & Technology How is a TP procedure usually structured (if it exists)? How should the TP procedure be written to be operational: task description & scheduling Statement of intent in terms of TP compliance Key considerations in terms of I/C flows PLI (Profit Level Indicator) to use for key flows Who to contact for new I/C flows Goods How To: Use Budget & Forecast numbers Segment P&L Calculate TP Update price in ERP Generate & book TP true-up Service How To: Not an operational document for Finance/SSC Determine cost base & cost components (shareholder, passthrough and conversion) Collect and apply allocation Keys Generate & book VAT invoice 2017 Deloitte Belgium 19

20 TP Delivery Aligning Data Flows with FP&A Cycle People & Organization Policy & Process Data & Technology FP&A Finance Cycle Budget 1 Calculate Transfer price to be applied to each I/C flow 2 5 Process I/C invoice according to calculated transfer price 3 Forecasts Actuals 4 Control Profit Level (PLI) of routine functions: monitoring & adjusting 2017 Deloitte Belgium 20

21 Operationalizing Transfer Pricing Maturity Level Assessment Score Card (Illustration) Ex-ante documentation TP procedures Calculate Process Control Ex-post documentation People & Organization Policy & Process Data & Technology Strong Weak 2017 Deloitte Belgium 21

22 Session 2 Address Common Challenges Indirect Tax, Management Reporting and System Data Gaps 2017 Deloitte Belgium 22

23 Implementing a TP Policy Address Common Challenges 1. Manage E2E TP life cycle 2. Structure TP operations 3. Address common challenges Business model Defend Planning / Ex-ante documentation People & Organization Indirect Tax (Ex-post) Documentation TP Life Cycle TP procedures Policy & Process Management Reporting Control Calculate Data & Technology System Data Gaps Plan Process Operate Defend 2017 Deloitte Belgium 23

24 Transfer Pricing and Indirect Tax Two Different Worldviews Indirect Tax Mgt. Reporting Data Gaps Transfer Pricing Profit allocation Routine margin Remuneration of intangibles Impact on Indirect Tax Supply of goods & services Place of supply Supply value Routine margin Upward adjustment Obtaining the right profit based on functions, assets and risk Applying the right tax based on transaction type 2017 Deloitte Belgium 24

25 Typical Indirect Tax Challenge Case 1 TP True-Up Upward Adjustment and Credit Note Entrepreneur Distributor (LRD) I/C Goods supply Transfer Pricing LRD remuneration is too LOW Impact on Indirect Tax Prices used for purchase of IC goods are too HIGH Routine margin } Upward adjustment Decrease inventory valuation & COGS Take no action Issue credit note Take no action Issue credit note CIT exposure for LRD Import fees & duties leakage Intrastat reporting Reference to original invoices 2017 Deloitte Belgium 25

26 Typical Indirect Tax Challenge Case 2 TP True-Up Downward Adjustment and Debit Note Entrepreneur Distributor (LRD) I/C Goods supply Transfer Pricing LRD remuneration is too HIGH Impact on Indirect Tax Prices used for purchase of I/C goods are too LOW Routine margin } Downward adjustment Increase inventory valuation & COGS Take no action Issue debit note Take no action Issue debit note CIT exposure for Entrepreneur (Except in some countries where downward adjustments are not CIT deductible leading to double taxation) Import fees & duties exposure Intrastat reporting Reference to original invoices 2017 Deloitte Belgium 26

27 Typical Indirect Tax Challenge -3 TP True-Ups as Marketing/Sales Support Service Allocation Main Supply Correction Entrepreneur Distributor (LRD) Entrepreneur Distributor (LRD) I/C Goods I/C Services Case 1 LRD remuneration is too LOW LRD needs to be remunerated for its local marketing support Routine margin } Upward adjustment Buyer Local marketing support Seller Case 2 LRD remuneration is too HIGH Entrepreneur needs to be remunerated for its sales support Routine margin } Downward adjustment Seller Buyer Sales support 2017 Deloitte Belgium 27

28 TP True-Ups as Marketing/Sales Support Service Allocation Difference in Transfer Pricing & Indirect Tax Reasoning Transfer Pricing Reasoning Transfer Pricing LRD guaranteed routine Reasoning margin is based on mutual services performed by both the LRD and Entrepreneur Distribution agreement describes services performed by LRD & Entrepreneur and mutual obligations Distribution agreement is aligned with facts (i.e. headcounts in LRD and Entrepreneur performing services mentioned) Indirect Tax Reasoning Qualification of supply: Supply provider (Entrepreneur vs. LRD) can alternate from one period to the other Supply value: Supply value can vary based on LRD profit margin Place of supply: Local marketing service from LRD can trigger nonrecoverable foreign VAT for the Entrepreneur in some countries Indirect Tax Exposure 2017 Deloitte Belgium 28

29 } Resolving Transfer Price and Indirect Tax Requirements Conflicts TP True-Ups Pro Active Price Adjustments (1) Entrepreneur Main Supply Distributor (LRD) 1 Set up transfer price 2 Calculate Actuals YTD margin 3 Extrapolate year-end margin I/C Goods TP1 1 Routine margin 3 Routine margin } 2 Q1 Q2 Q3 Q Deloitte Belgium 29

30 } } Resolving Transfer Price and Indirect Tax Requirements Conflicts TP True-Ups Pro Active Price Adjustments (2) Main Supply 4 Calculate upward/downward adjustment on extrapolated year-end margins Entrepreneur Distributor (LRD) 5 Calculate new transfer price for upcoming quarters I/C Goods 6 Set up new transfer prices TP1 TP2 6 5 TP2 Routine margin } 4 Q1 Q2 Q3 Q Deloitte Belgium 30

31 Resolving Transfer Price and Indirect Tax Requirements Conflicts TP True-Ups Pro Active Price Adjustments (3) Key benefits Steer Year-End YTD margins with transfer prices updated on a periodical basis Aligned with TP requirements (reach routine margin) Aligned with Indirect Tax (VAT, Customs requirements): consistent supply of goods Points of attention Transfer Price calculation Increase frequency to avoid big swing from one period to another Simulation tool to manage: Volume, product mix, overhead cost allocation Constraints (e.g. Transfer Pricing above product cost, regulatory price,...) As If scenarios (e.g. stock increase, stock duration, ) Automated interface to ERP to manage regular price updates 2017 Deloitte Belgium 31

32 Transfer Pricing and Management Reporting Two Different Worldviews Indirect Tax Mgt. Reporting Data Gaps Transfer Pricing Legal entity Routine vs. entrepreneur Controlling transfer price Management Reporting Product line / Business unit End to End margin Eliminating transfer price Manufacturer Distributor Manufacturer Distributor Costs Revenues Transfer price Supply chain Residual profit Routine margin E2E margin Profit allocation based on value drivers Optimizing E2E margin 2017 Deloitte Belgium 32

33 When Transfer Prices & Management Reporting Conflict Inventory Valuation/COGS Accounting Challenge Example Manufacturer Distributor Costs (*) Revenues Transfer price Standard (actual) cost { Material Labor Machine Standard (actual) cost TP margin Standard (actual) cost E2E margin (*) simplified: real case also contains packaging and transportation costs & overhead Transfer Pricing Distributor COGS Transfer price Management Reporting Distributor COGS Standard (actual) cost 2017 Deloitte Belgium 33

34 When Transfer Prices & Management Reporting Conflicts Inventory Valuation/COGS Accounting Solution Example 1 Booking inventory at standard cost, expensing TP margin Inventory (B/S) Standard cost 100 IC AR/AP (B/S) Transfer Price COGS booked at standard cost Inventory (B/S) Standard cost 100 PPV (*) (P&L) TP margin 10 Standard cost 100 COGS (*) PPV = Purchase Price Variance 2 Manage COGS account roll-up: Transfer Pricing vs. Management Reporting Transfer Pricing COGS & PPV Standard cost 100 TP margin 10 Management Reporting Standard cost 100 COGS (*) (*) PPV is left Below the Line in the Management Roll-Up 3 Re-Classify PPV to inventory for unsold stock at year-end for statutory reporting 2017 Deloitte Belgium 34

35 Transfer Pricing and Management Reporting Key Principles TP Components should be booked Below The Line Transfer Pricing Ensure that all TP components are Below the line Management Reporting Focuses on Above the line, i.e. what can be managed by the Business Finance managers Dedicated TP GL account or subaccount in management GAAP Set up management vs. statutory accounting roll-up Configuration of BI management and statutory report dual GAAP Sales (COGS) (Overhead) Management OP (I/C services) (I/C TP components) (I/C TP true-ups) Statutory OP Above the line: should not contain any TP component Below the Line: will be eliminated during I/C elimination 2017 Deloitte Belgium 35

36 Transfer Pricing & System Data Gaps Common Issues Data Indirect Tax Mgt. Reporting Data Gaps 01 Budgets are prepared using Management Reporting dimensions but not legal entity dimensions: Business Units Product Group Market /Customer Group 04 by If EBIT Budget & Forecast can be linked to a legal entity, there is no automatic segmentation function 02 Forecasts do not usually contain volume information (only monetary equivalent) 05 Budget, Forecast and Quarterly Actuals are usually in management GAAP (IFRS, US GAAP) vs. local GAAP 03 Budget & Forecast are externally focused and do usually not contain I/C margin on tangible goods I/C recharge of services 2017 Deloitte Belgium 36

37 Transfer Pricing & System Data Gaps Common Issues Technology 01 Challenges in getting adequate reports for calculation purposes BI reports: gross margin by product and EBIT reports GL account analysis: manual GL journals/postings PPV, inventory valuation 03 Challenges in updating ERP back Pricing procedures/tables update I/C invoice processing (TP true-up) 02 Complex calculations in Excel spreadsheets to manage Mapping Reconciliation Segmentation Simulation Output reports 2017 Deloitte Belgium 37

38 Transfer Pricing & System Data Gaps Common Solutions Long Term Data Data Rules & formulas Short & Medium Term Extrapolation IFRS to Stat adj. Extrapolating volume forecast EBIT segmentation by product SKU Technology Pricing & modelling tool Benefit of Excel in terms of flexibility and user-friendliness Additional functionality Audit trail - update Server storage Workflow Part of ERP/EPM upgrade (S/4 HANA) Entity dimension I/C service recharge Fully loaded entity P&L 2017 Deloitte Belgium 38

39 Session 3 Case Study Applying Technology to manage E2E Process for Transfer Pricing on Goods 2017 Deloitte Belgium 39

40 Demo Case Luminova: Manufacturer of Lighting Systems HQ based in Geneva, Switzerland 3 sales organizations in Belgium, the Netherlands and France 2 production plants: Belgium and France 1 Shared Service Center in Czech Republic Luminova has a Swiss principal company Headcount: 320 employees NL10 Sales Organization Sales Organization & Plant Shared Service Center (SSC) Principal BE10 FR10 CZ30 CH Deloitte Belgium 40

41 Demo Case Luminova Organizational Structure Group Legal entities Functions Luminova BE10 FR10 NL10 CZ30 CH10 Manuf. Distr. Manuf. Distr. Manuf. SSC Principal 2017 Deloitte Belgium 41

42 Demo Case Luminova TP Pricing Model Structure Goods flow Goods flow Clients Sells at C Invoice flow Manufacturing Company Sells at A Invoice flow Principal (HQ) Sells at B Invoice flow Distributing company NCP% Manuf. margin Budget Standard cost A Principal margin Manuf. margin Budget Standard cost B OM% Sales margin Principal Margin Manuf. margin Budget Standard cost C Sale Price composition 2017 Deloitte Belgium 42

43 Demo Case Luminova TP Pricing Model Assumptions TP benchmarking methods TNMM method is used with the following PLIs: NCP for manufacturers and OM for distributors. ERP TP setup Manufacturer is a cost plus on standard cost and distributor resale minus on list price. Production costs & inventory For demo purposes, we have assumed that the labor costs & the cost of raw materials are consistent between countries the sales volume will be equal to the production volume Deloitte Belgium 43

44 Demo Script Luminova Data Flow ACTUALS BUDGET Q1 FORECAST Step 0 Step 1 Step 6 Actuals FY16 load User legend Sales Manager Supply Chain Manager Finance controller Tax Manager Perform top-down Sales budgeting Step 2 Review top-down budget and perform bottom-up Sales budgeting Step 3 Budget production costs and calculate COGS Step 4 Budget OPEX, IC service recharge & Allocation of OPEX Step 5 Transfer price calculation for budget & review of financial statements Actuals load first three months FY17 Bottom-up Sales forecast Step 7 Step 8 Copy OPEX and COGS budget to forecast Step 9 Transfer price calculation for budget & review of financial statements Maintenance of user roles, access rights and master data changes * Idem as Q1 Forecast steps 2017 Deloitte Belgium 44

45 Operational TP Tool Demo Solution built in Anaplan 2017 Deloitte Belgium 45

46 Transfer Pricing Modelling in Anaplan Key Benefits 2017 Deloitte Belgium 46

47 Conclusion 2017 Deloitte Belgium 47

48 Conclusion Key Messages Manage the full E2E TP Cycle Not only your transfer pricing documentation Write a detailed transfer pricing policy A standard operating procedure for Finance, SSC and the IT team, including Indirect Tax aspect Apply technology Use tools to integrate transfer pricing with the FP&A finance cycle. Tailored tools can be easily built (e.g. Anaplan) 2017 Deloitte Belgium 48

49 Conclusion Next Steps 1 Complete a detailed Maturity Level Assessment Where are the gaps? 2 Make a business case for an operational transfer pricing tool E2E TP process cannot be effectively managed without technology 2017 Deloitte Belgium 49

50 How To Get Started Deloitte s Quick Start Operational TP Lab Business model Defend Planning / Ex-ante documentation One day workshop (Ex-post) Documentation TP Life Cycle TP procedures All key operational TP stakeholders Maturity assessment (Risks & Opportunities) Control Calculate Defining the end state Plan Operate Process Drafting an action plan Defend 2017 Deloitte Belgium 50

51 Contacts 2017 Deloitte Belgium 51

52 Contacts Jeroen Lemmens Partner Company: Deloitte Office: Zaventem Telephone: jlemmens@deloitte.com Liesbet Nevelsteen Partner Company: Deloitte Office: Zaventem Telephone: lnevelsteen@deloitte.com Thierry Chaumantin Senior Manager Company: Deloitte Office: Zaventem Telephone: tchaumantin@deloitte.com Jérôme Libioul Manager Company: Deloitte Office: Zaventem Telephone: jlibioul@deloitte.com 2017 Deloitte Belgium 52

53 Appendix 2017 Deloitte Belgium 53

54 Introduction to Anaplan Company and product key facts 2017 Deloitte Belgium 54

55 Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as Deloitte Global ) does not provide services to clients. Please see for a more detailed description of DTTL and its member firms. Deloitte provides audit, tax and legal, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte has in the region of 225,000 professionals, all committed to becoming the standard of excellence. This publication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the Deloitte Network ) is, by means of this publication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this publication Deloitte Belgium