Belgium: Trends to consider for 2026 transfer pricing audits

Expanded information requests and coordinated approach across tax areas

The Belgian tax authorities (BTA) initiated the 2026 transfer pricing audit wave in January, issuing transfer pricing-related information requests to Belgian taxpayers. Recent trends show these requests are increasingly supplemented by additional demands throughout the year.

Standard transfer pricing questionnaires with 32 questions and pre-filing meeting invitations have been sent by the BTA's Transfer Pricing Cell. The questionnaires aim to gather insights into daily activities and intercompany transactions, featuring tailored questions based on submitted transfer pricing documentation.
Transfer pricing audits may expand to include corporate income tax and value added tax (VAT), particularly in the financial services sector.
A coordinated approach within the BTA is evident, as some taxpayers receive questionnaires from general corporate tax inspectors.
Group-wide audits are emerging, covering transfer pricing, VAT, and corporate income tax.
Transfer pricing audits now include questions on individual (personal) tax, permanent establishment, withholding taxes, and beneficial ownership.
Operational transfer pricing questions in enterprise resource planning (ERP) systems are included, emphasizing the need for robust systems due to detailed requests from tax authorities.

Read a February 2026 report prepared by the KPMG member firm in Belgium

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.

Relevant Results

Belgium: Trends to consider for 2026 transfer pricing audits

Contact KPMG

Headline