Transfer Pricing audits

On 24 September, the Belgian Constitutional Court confirmed that the legal challenge against Belgium’s Pillar Two UTPR can continue, despite the publication of the OECD Side-by-Side Package and the European Commission’s notice concerning it. In this podcast, Jean-Philippe Van West discusses the Court’s decision, the implications for Belgian subsidiaries of multinational groups, the next steps before the Court of Justice of the European Union, and what businesses should do in the meantime. For a broader discussion of recent Pillar Two and international tax developments, join our International Tax Webinar on 8 October 2026 at 16:00 CEST.  Register here: https://www.pwc.be/en/events-courses/2026/international-tax-webinar-october-2026.html  Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

CBAM is no longer just a border compliance topic it is becoming a real transfer pricing issue for multinational groups. As carbon costs enter cross-border value chains, companies need to ask where those costs should land, i.e., with the importer, the principal, the manufacturer, or another group entity.  In this episode, Helena Caluwé, Pieter Dere and Joris Reijnierse explore: How CBAM affects function and risk analysis, intercompany pricing, benchmarking, year-end adjustments and transfer pricing documentation; Why consistency between CBAM data, customer pricing, ESG reporting and transfer pricing documentation will be critical given that tax authorities’ scrutiny in this area is envisaged. Overall, a practical conversation for CFOs, tax directors and transfer pricing teams preparing for the financial and tax impact of CBAM. Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

Most companies treat CBAM as a cost to absorb. The smarter ones treat it as a pricing decision - and turn it into a competitive advantage. But there's no single right answer. Your move depends on two things: your carbon-cost position versus competitors, and your customers' willingness to pay. In this episode, Pieter Deré, Helena Caluwé and Romain Matriche break it down across three questions: ✅ WHICH strategy? The 4 pricing responses to CBAM - selective pass-through, low-carbon premium, margin pressure, and price-led share gain. ✅ HOW to execute it? The Assess → Strategize → Execute playbook: segment your customers, model the margin impact, and equip your sales teams. ✅ HOW to stay defensible? Why your customer narrative, your pricing, and your tax & sustainability disclosures must all tell the same story - before the authorities cross-check them. Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

This podcast highlights the main topics discussed and insights gained during PwC’s International Tax Webinar of 1 July 2026, which focused on a number of important recent developments in the area of European and international tax law and transfer pricing. This episode of the podcast first provides an update on the state of play regarding Pillar Two compliance, where efforts continue despite the filing deadline of 30 June. Subsequently, a short update is provided on the Tax Omnibus proposal, which puts forward several important amendments to six direct tax directives — the Parent-Subsidiary Directive, the Interest and Royalties Directive, the Tax Merger Directive, the Anti-Tax Avoidance Directive (ATAD), the Dispute Resolution Mechanism Directive and the FASTER Directive. The focus is on the most salient aspects of that proposal and the (minor) differences compared to the earlier (publicly leaked) version of the proposal, which was already discussed during an earlier episode of the podcast. After that, the discussion turns to the recently published proposal for a recast of the Directive on Administrative Cooperation (DAC), which aims to create more legal certainty and cut red tape for businesses in respect of compliance and reporting obligations. It does so by bringing the DAC and its eight amendments together into a single text and by introducing a number of targeted simplifications, in particular under DAC 6 (including a Pillar Two carve-out and an extended reporting deadline), DAC 7 and the notification obligations under DAC 4 and DAC 9. The podcast then turns to the public consultation on the update of Chapter 7 (intra-group services) of the OECD Transfer Pricing Guidelines. While an earlier episode of the podcast went into detail on the main changes in the discussion draft, this episode shares three key takeaways from the webinar's polling questions on how service transactions are structured within organisations. Finally, some insights are provided on what we can expect in the upcoming months in terms of international and European tax policy developments. Are you interested in listening to the recording of the International Tax Webinar and the slides? Reach out to Pieter Deré to obtain access.Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

As announced in episode 58, we’re launching a series of podcasts on tax audits. In this episode Pieter invited Stefaan Dewachter, Gill Van Damme and Véronique De Brabanter to talk about practical data readiness for tax audits, particularly in the Belgian jurisdiction but applicable globally. They will provideguidelines to CFOs, tax directors, and controllers on how to prepare their bookkeeping and data environments to be audit-ready, emphasizing traceability, consistency, and governance.  They will give an insight into what tax authorities may require and how to address these requests in an adequate manner. Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

In this second episode of our CBAM mini-series, Pieter is joined again by Helena Caluwé and Aurélien Denis to go one level deeper: what does CBAM actually mean for businesses? Beyond the compliance filings, CBAM is fundamentally a governance and financial management challenge. Our experts take listeners under the hood of the CBAM cost calculation — embedded emissions, CBAM certificate price linked to the EU ETS, the CBAM factor escalating from 2.5% in 2026 to 100% by 2034, the carbon price rebate, and the role of import volumes — to show why the true financial exposure is far higher than many companies anticipate. They explain why CBAM should land on the CFO and tax director's agenda: compliance risks, cost control and forecasting, and the very real cash impact on margins, working capital and operating cash flow. We also discuss CBAM as a cross-functional business programme — touching procurement, customs and trade, finance, tax, sustainability, legal, IT and commercial — and share concrete priorities for businesses right now: mapping imports against CN codes, engaging suppliers to collect actual emissions data, modelling financial exposure, applying for authorised CBAM declarant status, and exploring optimisation opportunities such as bonded warehouses or inward processing. Tune in! Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

The OECD just opened a public consultation on a revised Chapter VII of the Transfer Pricing Guidelines covering intragroup services, with comments due 22 July and a public consultation in November. Whereas the objective is to align Chapter VII with Chapters I–III and add practical illustrations without changing underlying principles, the draft is actually a substantial rewrite of the existing Chapter VII. In this podcast, Gilles Franssens and Jens Kiekens discuss key changes included in the discussion draft, when and how this could start having an impact, as well as what companies should do to get prepared.  Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

The European Commission’s proposal for a Tax Omnibus Directive has been leaked ahead of its official publication later this month.  The Tax Omnibus Directive aims to simplify the EU direct tax framework, reduce compliance costs for businesses and, ultimately, improve the EU's competitiveness. To that end, it proposes to amend six existing direct tax directives in one go: the Interest and Royalties Directive, the Parent-Subsidiary Directive, the FASTER Directive, the Tax Merger Directive, the Anti-Tax Avoidance Directive, and the Dispute Resolution Mechanisms Directive. Many of the proposed amendments are highly ambitious. Find out more in this podcast about what the leaked proposal for a Tax Omnibus Directive has to offer! Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

Welcome to the first episode of our new Tax Bites mini-series dedicated to the Carbon Border Adjustment Mechanism (CBAM) and the broader EU carbon taxation landscape. In this opening episode, Pieter sits down with our CBAM experts, Helena and Aurélien to set the stage: how does CBAM fit into the wider EU Green Deal and Fit for 55 package, how does it interact with the EU Emissions Trading System (ETS), and why does it matter now more than ever? Our experts unpack the latest ETS and CBAM updates — from the phase-out of free allowances and the tightening of benchmarks, to the launch of the definitive period on 1 January 2026, the CBAM Omnibus simplification package, the refined methodology on embedded emissions, the proposed deduction for carbon prices already paid in third countries, and the proposed scope expansion to downstream iron, steel and aluminium goods from 2028. We also bust one of the biggest myths circulating in the market: the idea that CBAM "only costs 2.5% in year one". Spoiler — the real cost is materially higher. Tune in! Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

New Tax Bites episode out now! Pieter sits down with transfer pricing experts Ann and Brecht, and legal expert Véronique, to explore the changing Belgian TP audit landscape. Discover what happened to the traditional February audit "wave", how audits are evolving and which companies and topics are being targeted. Get practical tips on prevention, managing the audit process, and resolving transfer pricing disputes.Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites