Belgium: Overview of tax audits of multinational entities

Belgium: Tax audits of multinational entities

The Belgian tax authorities, starting from 2018, decided to take tax audits of multinational enterprises to the next level—focusing on transfer pricing and complex international tax issues (resulting from, among other items, implementation of the Anti-Tax Avoidance Directive).


This action by the tax authorities resulted in a significant reinforcement of personnel involved in transfer pricing audits (i.e., through the Special Transfer Pricing Audit Division), as well as to the increased overall cooperation within the Large Enterprises Department and the Special Investigation department of the tax authorities in an effort to strengthen tax audits in these areas.

Given the circumstances of the coronavirus (COVID-19) pandemic, the Belgian tax authorities have been taking a proactive approach in considering the tax and transfer pricing-related implications of the COVID-19 crisis, creating special internal workgroups and conducting “brainstorming” sessions on changes arising from the current economic situation. Going forward, the tax initiatives to support the economic recovery in the pandemic will be closely intertwined with the increase in tax transparency trends, as well as a focus of the tax authorities on addressing tax avoidance, evasion, and non-compliance.

Read a March 2021 report prepared by the KPMG member firm in Belgium that provides a guide for multinationals on the general tax audit process, key take-aways, and expected developments

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