Transfer pricing services

Transfer Pricing in Belgium: Local expertise with a global reach

Operating in Belgium, a key gateway to the European market, means navigating some of the most stringent transfer pricing documentation requirements in the region. The Master File and Local File, Country-by-Country Reporting, and ever-increasing scrutiny from the tax authorities make transfer pricing a top priority for mid-sized and large businesses. Our local team, backed by a global network, delivers practical solutions to help you stay compliant while optimising your tax position.

Our approach

In Belgium, transfer pricing is subject to close attention from the tax authorities, supported by specialised audit teams and enhanced international information exchange. Managing these obligations effectively requires both in-depth local insight and coordinated international expertise. Our Belgian team works closely with colleagues across more than 100 countries to track developments such as changes in legislation, administrative guidance and court decisions, ensuring your policies remain fully compliant and aligned with global and local standards.

Our transfer pricing experts in Belgium have extensive experience in functional and value chain analysis, a vital tool to align transfer pricing with economic value creation. We combine this analytical capability with robust data solutions including access to commercial databases and cloud-based systems to support benchmarking, documentation and collaboration.

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your tax positions.

Our services

• Strategic advice on all aspects of transfer pricing
• Factual and functional analysis
• DEMPE analysis
• Value chain analysis and transformation
• Economic analyses, including commercial benchmarks, loan benchmarks, and royalty benchmarks
• Cash pools and other integrated group-wide financing systems
• Transfer pricing documentation including preparation of master file, local files and country-by-country reporting
• Transfer of functions/risks/assets, valuation of transfer packages, exit taxation
• Valuation of intangibles
• Transfer pricing controversy, both proactive measures (such as assistance with negotiating rulings/APAs), as well as reactive measures (e.g. support with audit defense and MAP cases)

Unlock the 2025 Transfer Pricing Rules in Belgium. 

Our tools & solutions

International companies are increasingly centralising and standardising their transfer pricing documentation to achieve efficient, comprehensive coverage. That’s where our seamless approach comes in.

Reptune, an OECD compliant transfer pricing documentation software, allows our global teams to easily monitor workflow management and ensure consistency across all locations. Doing this means you get a service that is fast, efficient and accurate.

It follows a top-down approach where data management starts from the global perspective of the multinational before drilling down to a single group company and its individual transactions.

The software’s dashboard provides visual insight into transaction flows, documentation progress and financial performance, while the status page helps prioritise the work based on local deadlines.

We also have access to various commercial databases, including TP Catalyst, Bloomberg and RoyaltyStat, as well as to technology-enabled solutions facilitating data exchange (through our Signals tool) and the preparation CbC reports.

Want to learn more? Get in touch with our team to explore our tailored solutions!