ARTICLE · 29 MAY 2024

2024 Transfer Pricing Audit Wave

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

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Vincent Vercauteren

Ellen Vandingenen

Elien Van Malder

The Belgian tax authorities recently initiated the 2024 transfer pricing audit wave, starting with a questionnaire and 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

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