Tax bites podcast – Transfer Pricing audits
New Tax Bites episode out now! Pieter sits down with transfer pricing experts Ann and Brecht, and legal expert Véronique, to explore the changing Belgian TP audit landscape. Discover what happened to the traditional February audit “wave”, how audits are evolving and which companies and topics are being targeted. Get practical tips on prevention, managing
Tax audits are picking up – But the wave is over
The era of the large-scale tax audit “wave” in February is over. Tax audits in Belgium are increasingly spread throughout the year, and they are becoming more targeted, data-driven and multidisciplinary. Here’s what you need to know. What’s behind the yearly uptick? The Belgian Tax Authorities (BTA) have moved away from the traditional model of launching large-scale, sometimes announced, thematic audit campaigns – including in transfer pricing (TP). February and March do, however, typically still bring a visible uptick in
New law providing various provisions – Key tax changes adopted by the Chamber
On 11 December 2025, after extensive discussions within the Finance Commission, the Chamber adopted the draft law providing various provisions. This legislation encompasses both corporate and personal income tax measures, alongside significant updates to tax procedures. From a corporate tax perspective, here are the key measures adopted: The “Sicav RDT / DBI Bevek” regime remains applicable, but a 5% tax will
Tax Bites Podcast – Amended penalty regime for first offence
Tax Bites Podcast on tax dispute mitigation With this podcast we kick off a series of podcasts on topics related to tax audits. In this first podcast we discuss the recent amendment to the penalty regime applicable to a first offence. Pieter interrogates his guests on the implications of this amendment and what this means
Belgian Tax Authorities push hard on Co-Operative Tax Compliance Programme (CTCP)
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
Transformative Indirect Taxes Reforms to Boost Sustainability, Efficiency, and Transparency in Belgium
As part of the recent government agreement, the new Belgian government has introduced a series of proposed changes in indirect taxes aimed at supporting sustainability, enhancing transparency, and simplifying the tax system. Below are the key highlights designed to create a more efficient fiscal environment that aligns with climate objectives, reduces administrative burdens, and combats
How key interest rate cuts and stabilising inflation might impact your transfer pricing policy
The past few years the financial markets have been characterised by a significant increase in interest rates battling the surge in inflation throughout the world. Since the arm’s length principle requires intercompany transactions to appropriately reflect current market conditions, these exogenous elements have led companies to update their financing policies and more specifically their transfer
Circular letter relating to the settlement of cross-border tax disputes in the European Union
On 1 December 2023, the Belgian tax authorities issued a circular letter (2023/C/95) relating to the settlement of cross-border tax disputes in the European Union. This circular letter provides clarification to help overcome the difficulties that may arise in the interpretation or application of the law of 9 May 2019 implementing Council Directive (EU) 2017/1852
