Belgium: Recent trends in transfer pricing audits

Overview of recent trends in transfer pricing audits in Belgium

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March 14, 2025

In recent years, tax authorities in Belgium begin the year by initiating transfer pricing audits and sending related information requests to a number of Belgian taxpayers. Typically, over 300 requests for information are sent at the beginning of the year, and additional information requests are sent throughout the remainder of the year. 

These transfer pricing audits are indicative of the following trends:

  • Growing capacity within the Belgian tax authorities to perform transfer pricing audits
  • Increased emphasis on Belgian transfer pricing compliance requirements
  • Expansion of the scope of requested information
  • Process analysis (tell me, show me, prove to me)
  • Increased likelihood of group audits

Read a March 2025 report prepared by the KPMG member firm in Belgium

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