Transfer Pricing Services

At Forvis Mazars we provide you with transfer pricing services. Market research consistently shows that for international business, transfer pricing continues to be the most significant international tax issue.

Transfer pricing in Belgium: compliant, defensible and practical OR local expertise with a global reach

Operating in Belgium, a key gateway to the European market, means navigating detailed transfer pricing requirements, increasing tax authority scrutiny and enhanced international information exchange. For mid-sized and large internationally active businesses, transfer pricing has evolved beyond an annual documentation exercise. It is now a strategic tax, finance and governance priority.

Forvis Mazars helps clients design, document, implement and defend transfer pricing policies that are aligned with value creation, supported by reliable data and pragmatic in execution. By combining local technical expertise with the global reach of the Forvis Mazars network, we support clients across the full transfer pricing lifecycle, from Belgian documentation and benchmarking to multi-country projects, business restructurings, tax certainty and dispute prevention.

Our objective is simple: transfer pricing that can be explained, implemented and defended.

Our approach

Effective transfer pricing starts with a clear understanding of the business model, value chain and intercompany transactions, enabling a focused diagnostic review of transfer pricing risks and opportunities. This enables us to identify material transactions, documentation gaps, audit exposures, benchmarking needs and potential areas for improvement.

Based on this assessment, we develop a tailored work plan. Depending on your needs, this may include documentation support, benchmarking and economic analysis, transfer pricing model design, implementation support, coordinated multi-country documentation, business restructuring assistance, tax certainty or dispute prevention.

Working closely with Forvis Mazars colleagues across more than 100 countries, we deliver advice that is locally grounded, internationally consistent and practical to implement. Our focus is on proportionate, audit-ready and commercially relevant solutions.

Our services

2 people sitting and looking at a laptop while explaining something

TP strategy & policy design

Practical transfer pricing policies aligned with how your business creates value and operates in practice.

2 people standing in an office and discussing something

Global TP documentation & compliance

Coordinated master file, local file, (Public) CbCR and TP filing support across jurisdictions.

Benchmarking & economic analysis

Robust economic analyses for goods, services, financial and IP-related transactions.

Business restructuring & value chain

Transfer pricing support with operating model changes, centralisation and transfers of functions, risks or assets.

Financial transactions and treasury TP

Arm’s length support for intercompany loans, cash pooling, guarantees and group financing.

Intangibles, DEMPE & IP remuneration

Analysis of IP ownership, DEMPE functions, licence or franchise models and intangible-related remuneration.

Tax certainty & dispute prevention

Ruling, APA and risk-review support to reduce uncertainty before disputes arise.

TP controversy & dispute resolution

Technical and strategic support during TP audits, MAP and double-taxation cases.

Operational transfer pricing

Processes, agreements and controls that make transfer pricing work in practice.

International TP regulatory developments

Assessing how Public CbCR, Pillar Two, Amount B and other developments affect transfer pricing policies, documentation and reporting.

Technology-enabled delivery

International groups increasingly need a centralised, consistent and data-driven approach to transfer pricing. We combine technical transfer pricing expertise with technology-enabled delivery to improve efficiency, transparency and control across jurisdictions.

Our approach supports structured data collection, collaborative documentation workflows, benchmarking, financial analysis, (Public) Country-by-Country Reporting, deadline monitoring and management reporting. We use recognised commercial databases and technology-enabled solutions to improve consistency and facilitate collaboration between local and global teams.

Where appropriate, we also use automation and responsible GenAI-enabled support to streamline parts of the transfer pricing process, while ensuring that technical judgement, senior review and audit-defensible conclusions remain central to our work.

Our benchmarking and economic analysis work is supported by recognised commercial databases and data sources, including TP Catalyst, Bloomberg and RoyaltyRange, as well as other solutions for secure data exchange, (Public) CbCR support and project management.

Why Forvis Mazars?

Practical, proportionate and defendable

We combine technical transfer pricing expertise with a pragmatic understanding of how businesses operate. Our approach is designed to help clients meet their compliance obligations, reduce audit risk and implement transfer pricing policies that are workable in practice.

Local expertise, global reach

Our Belgian team understands the local documentation requirements, audit environment and practical expectations of the Belgian tax authorities. At the same time, we draw on the Forvis Mazars international network to help ensure consistency across jurisdictions.
Integrated tax, accounting and audit perspective
Transfer pricing often interacts with corporate income tax, indirect tax, accounting, statutory reporting and audit requirements. We work closely with other Forvis Mazars specialists to ensure that transfer pricing positions are aligned with the broader tax and financial reporting context.

Senior-led support

Clients benefit from senior involvement throughout the engagement, from scoping and technical review to discussions with management, finance teams and tax authorities.

Unlock the Tranfer Pricing Rules

Forvis Mazars has developed a tool that allows users to identify and compare local country transfer pricing requirements across a number of jurisdictions, from all continents.

Transfer Pricing Rules

Let's discuss your transfer pricing needs

Whether you require support with compliance, advisory or complex transfer pricing matters, our team is ready to help. Request a proposal to get started.

Request for proposal

Newsletters

11 May 2026

Transfer pricing compliance FY 2025

As the Belgian transfer pricing compliance season for FY 2025 approaches, we would like to remind you of the upcoming filing deadlines and highlight the enhanced Belgian transfer pricing documentation requirements.

14 Apr 2026

OECD Pillar One update

Simplifying the Arm’s Length Principle for routine marketing and distribution activities

Public Country-by-Country Reporting

With the first reporting deadline for Public Country-by-Country Reporting (Public CbCR or pCBCR) underway for many large multinationals (i.e. generally by 31 December 2026 for a calendar-year group), please find below a technical update following recent releases by the European Commission (EC) and the National Bank of Belgium (NBB).