Belgian Tax Authorities’ transfer pricing audit team is preparing for second wave of audits in early 2014

Tax Controversy & Dispute Resolution ()
As previously announced in our Alert of 24 January, the Belgian tax authorities (BTA) have decided to “shift gear” on Transfer Pricing (TP) audits. Further to the OECD BEPS Action Plan, TP is under worldwide scrutiny, and the BTA has been quick to take concrete steps: it increased the number of TP audits and expanded its audit team, with new internal hires. This alert also describes the file selection criteria, envisaged changes in the Belgian Income Tax Code, and the increased collaboration within the different Belgian government bodies and with foreign tax authorities.