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 nine years. The department also has access to a large team of economists, who are capable of performing 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.
The team recently assisted a US multinational TMT client in discussions with the Belgium tax authorities following a tax dawn raid focused on the functional profile of the Belgium office, the intracompany agreements with the principle company and analysis of the arms-length profits of the company.
Deloitte is one of the leading global firms active in transfer pricing. The team in Belgium is led by partner Patrick Cauwenbergh. A number of partners support him in Belgium, notably, André Schaffers who coordinates Deloitte’s Global Economics Network. 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.
Deloitte recently advised a multinational software and hardware company on a global profit split model following the acquisition of a large competitor. The profit split model was designed to counteract the adverse effects of any withholding taxes, as well as aligning the company with all BEPS policy as well as obtaining an APA for Belgium and Germany.
The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.
Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.
Liedekerke Wolters Waelbroeck Kirkpatrick is a Belgium based law firm, with a transfer pricing team focused on advice pertinent to obtaining transfer pricing rules from authorities and representing clients in transfer pricing-related litigation.
The team recently represented an international group before the Antwerp court of appeal in a case put forward by the authorities that a cross-border share transfer conducted during a group reorganisation was not conducted in line with arms-length principles. Following this case, which was won by the taxpayer, the authorities levied another assessment on the same principle, which is currently pending before the Court of Cassation.
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 firm has advised a number of multination corporations, including an international real estate group in the determination of appropriate remuneration for intercompany financing, in line with the arm's length principle. The team also advised a large automotive manufacturer on the impact of the enlarged permanent establishment definition on their commissionaire structure, including analysis of their profit allocation structure.
Mayer Brown’s European transfer pricing department is coordinated from the office in Brussels, with partner Astrid Pieron leading the European transfer pricing centre. The TP team works across all TP areas, with a strong focus in the M&A and financial sectors. The firm assists with all necessary policy adaptation and creation, as well as documentation assistance and representation in audits and disputes.
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.