Thursday, 11 April 2024

2024 transfer pricing audit wave

The Belgian tax authorities recently initiated the 2024 transfer pricing audit wave, starting with a questionnaire an a pre-audit meeting. 

The tax authorities (transfer pricing audit team) initiated the 2024 TP audits by sending out TP questionnaires to various companies. Also other audit teams, such as the Large Companies team or the Special Investigation Squad started issuing TP questionnaires.  A number of companies already received inquiries in which the tax authorities are examining the group's transfer pricing. This is just the start, as more and more companies will receive such questionnaires and invitations for a pre-audit meeting in the coming weeks.

It is noteworthy that the tax authorities no longer limit their focus to multinationals but are increasingly conducting TP audits of SMEs. Today, a vast majority of tax audits are triggered through AI-based tools for target selection. The transfer pricing forms are also a source of information for tax authorities to select files and the non-compliance of filing these forms could trigger audits as well as loss making entities, group restructurings, financial transactions, etc.

 We also note that, based on the law of 20 November 2022, amendments to the investigation, assessment, objection, and retention periods entered into force as from tax year 2023 (i.e., financial years closing as from 31 December 2022). The current three-year investigation period is extended to six years when the tax return includes certain international elements, such as transfer pricing documentation.

For initial help in preparing for a TP audit, you can always consult our updated website: TP Audit - Benelux transfer pricing audit services. This ultimate guide provides you with an overview of all typical and possible (next) steps of the TP audit process as well as recommendations to prepare for a TP audit.


Being prepared for a TP audit has become essential these days given the substantial level of information that needs to be provided in a short timeframe. We, as economists of Tiberghien economics, work together with tax lawyers of Tiberghien as one multidisciplinary team having vast experience in dealing with tax and/or transfer pricing audits. Our team consists of highly experienced people with in-depth knowledge in the domains of tax, transfer pricing and procedural aspects including litigation.

Tine Slaedts & Patrik Pashaj from Tiberghien Economics

Vincent Vercaureren, Ellen Van Dingenen & Elien Van Malder from Tiberghien Lawyers.