Belgium



World TP Reviews

Transfer pricing
Aptis Global

Aptis Global is a transfer pricing boutique founded in 2017 serving cross-border multinationals in controversy litigation, audit defence, compliance, and documentation. Investment funds, transportation and commodities trading clients are recurrent custom. Co-founders Kathrine Kimball and Sofie Stas are key firm contacts.

Last year the firm created global documentation for a company that had spun-off from a conglomerate parent in a post-separation year, highlighting transactional risk thereon. An American conglomerate received counsel on post-merger alignment challenges in the consumer goods sector.

Arteo Law

Arteo Law is a Brussels-based independent boutique law firm which offers transfer pricing advice, assistance in TP litigation and secures rulings. The transfer pricing team includes partner Steven Peeters. 

The transfer pricing team provided incisive expertise in a Supreme Court appeal that validated an assessment relating to intragroup debt restructuring. A further dispute was won for a US multinational against the Belgian Transfer Pricing Unit.

Baker McKenzie

Baker McKenzie is well known for its presence in the European transfer pricing market. The team in Belgium is led by Géry Bombeke, who has been a partner in the tax department for more than 10 years. The department also has access to a large team of economists, who can perform economic analysis and modelling for clients. The firm advises on transfer pricing policy design and implementation, as well as negotiating unilateral, bilateral, and multilateral APAs, MAPs and assisting in transfer pricing disputes. 

Recently, the team assisted several multinationals from across the globe in complex transfer pricing modelling, audits, and disputes. It also participated in litigation concerning dividend received deduction on the Danish case precedent.

Associate Dieter Geuens was hired from EY in January 2020. 

Deloitte

Deloitte is one of the leading global firms active in transfer pricing. The team in Belgium is led by partner Patrick Cauwenbergh. Several partners support him in Belgium, notably, Jeroen Lemmens who is one of the three global technology leaders within Deloitte for transfer pricing. The partners are supported by a large team of junior professionals including lawyers and economists. The firm advises extensively on transfer pricing policy, design, and implementation.

The team recently advised a private equity multinational, in the alignment of its operating model to realise competitive effective tax rates. The team assisted a homeware multinational with the implementation of a centralised principal entrepreneur model, coordinating all brands under a unified umbrella.

Loyens & Loeff

Loyens & Loeff offers transfer pricing services across the Benelux region, with closely linked teams in all regions. The Belgium TP team is led by Natalie Reypens, who is a recognised TP expert, as well as an expert in corporate and international tax law. Five other professionals assist her in the transfer pricing team. The team cover the full scope of transfer pricing issues ranging from compliance, documentation and interaction with other tax and legal issues, to negotiations with tax authorities and dispute resolution. 

Recently, the team assisted a multinational cosmetics company with the implementation of a new Benelux business model involving value chain analysis, benchmarking and BAPA negotiations. Intragroup financing policy was given to a consumables client.

Stibbe

Stibbe is a local, full-service law firm, which regularly advises on transfer pricing cases, in relation to litigious proceedings as well as in an advisory role. The transfer pricing team includes partner Henk Verstraete. The team was also represented in the AmCham transfer pricing work group, which aimed to discuss the recent transfer pricing circular letter with the tax authorities. 

Transfer pricing activity remains confidential.