The CTCP: A Growing pillar in Belgian tax compliance
The Belgian Tax Authorities (BTA) are intensifying their efforts to promote the Belgian Co-operative Tax Compliance Programme (CTCP), marking an important shift in the tax compliance landscape for large and very large enterprises in Belgium.
The Belgian CTCP aims to address the corporate need for a stronger, co-operative relationship with tax authorities. It promotes trust and transparency between large companies and the BTA. By providing a single point of contact and managing tax risks together with the taxpayer, the CTCP aims to enhance legal certainty and simplify tax compliance for eligible taxpayers. Currently, 10 groups (85 Belgian entities) participate in the program.
Following recent updates to the CTCP brochure and intake guidance (see our previous newsflash), the BTA has been proactively reaching out to “very large companies” over the past few months. They’ve sent approximately 450 invitations to Belgian enterprises for one-on-one virtual meetings to encourage participation in the programme.
Why is this important now?
The CTCP is not a passing trend, but here to stay. Drawing on international best practices and OECD recommendations, the programme is designed to foster a more collaborative, transparent, and proactive relationship between taxpayers and the Belgian tax administration. The BTA’s current outreach campaign – targeting “very large companies” (defined as those with an annual turnover exceeding EUR 750 million, a balance sheet total over EUR 1.5 billion, or more than 1,000 employees) – demonstrates the BTA’s desire to have CTCP become a cornerstone of Belgian tax compliance for large enterprises. The BTA’s longer term ambition is to have 50 groups participating in the CTCP.
Note that companies below these thresholds may also be eligible if they meet other requirements, such as having an effective TCF in place.
What about international initiatives?
In addition to the Belgian CTCP, international cooperative compliance programmes such as the European Trust and Cooperation Approach (ETACA) and the OECD’s International Compliance Assurance Programme (ICAP) are also available. These initiatives offer multinational groups the opportunity to engage with multiple tax authorities in a coordinated manner, rather than on a unilateral basis. Companies with cross-border operations should consider whether participation in these international programmes, alongside or instead of the CTCP, offers more benefits and aligns (more) with their global tax strategy.
The second pilot of ETACA will launch in late September 2025. Interested taxpayers can contact the tax administration of the Ultimate Parent Entity’s tax residence to submit an application. Read more about it here.
What does this mean for your organisation?
With the BTA’s proactive outreach, the CTCP is generating significant interest and many questions among large and very large companies, such as:
- What are other companies doing? (Peer and industry insight)
- Is our organisation ready to enter the CTCP? (requirements and/or eligibility criteria)
- How does the current state of your Tax Control Framework align with CTCP requirements?
- How can I enter the CTCP program with an informal Tax Control Framework?
- What about pending disputes or ongoing tax audits?
- Is the CTCP mature enough or is our organisation going to be a guinea pig?
- Will the (intangible) benefits outweigh the cost for our organisation? What is the cost? (cost-benefit analysis)
- How can we evaluate and decide whether joining the CTCP or another international program as ICAP or ETACA is the right decision for our company?
- How does the CTCP address confidentiality and data protection concerns?
Companies should assess their position and next steps in relation to CTCP. This may include assessing eligibility and readiness, performing a cost-benefit analysis for their organisation, considering strategic fit and company tax / governance profile, and reflecting on international programmes.
Interested in discovering more about the CTCP? Looking for a sparring partner to shape your position? Or want to start with (or further enhance) the design of your TCF? Visit our webpage, reach out to your regular PwC contact, or contact our CTCP / TCF experts Annelies, Brecht and Chiara.
