Assessment of transfer pricing risks, tax audits, and dispute resolution: how to prepare and defend your case

Transfer pricing is increasingly on the radar of tax authorities. In this session, you will learn how to proactively prepare your company for audits, manage risks, and efficiently handle tax discussions.

Content

With the increasing international focus on transfer pricing audits, it is crucial to be prepared. This training course helps you to identify risk areas in good time, proactively prepare a defense file, and respond appropriately to questions from the tax authorities. You will gain insight into the Belgian audit process, common challenges, and negotiation techniques. We will also discuss dispute resolution mechanisms such as MAP, arbitration, and—where necessary—legal proceedings.

Target group

This training course is aimed at tax and transfer pricing professionals, CFOs, corporate lawyers, and compliance officers involved in tax audits or the management of transfer pricing risks at home and abroad.

Duration

A physical session typically lasts 1.5 to 2 hours and is organized at the client’s premises. An online session lasts 1.5 hours.

Timing

We offer our training courses online or as customized in-company training courses tailored to the specific needs of companies. If you are interested, please contact us via the “REQUEST INFORMATION” button above. We will be happy to consult with you to schedule a session that fully meets your needs.

Programme

  • The audit process in Belgium: how does a transfer pricing audit work? Explanation of the typical steps in a Belgian TP audit: start-up, requests for information, meetings, preliminary findings, and conclusion. What can you expect?

  • Red flags and triggers for audits: What signals or reporting elements trigger an audit? Think of loss-making entities, restructurings, deviating margins, inconsistencies in documentation, etc.

  • Identifying transfer pricing risks: How do you map out risk areas internally? Understanding structures, transactions, and documentation that are potentially vulnerable.

  • Key challenges during an audit: Common problems, such as insufficient substantiation, flawed cost allocations, non-contemporary documentation, or lack of economic analysis.

  • Key challenges during an audit: Common problems, such as insufficient substantiation, flawed cost allocations, non-contemporary documentation, or lack of economic analysis.

  • Negotiating with the tax authorities: Strategies for effective communication and negotiation during and after the audit. How do you position yourself without making unnecessary concessions?

  • Dispute resolution: What if an audit leads to adjustments or double taxation? Overview of:

    • MAP (Mutual Agreement Procedure)
    • Arbitration procedures
    • Legal actions and considerations

  • Summary and Q&A: Closing with key insights and time for questions.