The Belgian tax authorities are placing increasing emphasis on transfer pricing (TP) and intragroup transactions during audits. Their focus is no longer limited to traditional, thematic transfer pricing audits, which typically begin in February and March. Transfer pricing-related questions are also becoming increasingly common during general tax audits.

Stricter documentation requirements apply to financial years starting on or after 1 January 2025. In addition, the deadlines for submitting transfer pricing documentation for financial year 2025 are fast approaching. We outline the main points to consider so that your company can prepare in good time.

Within international groups, it is common for employees of a Belgian company to participate in a share-based or incentive plan set up by a foreign parent company. A recurring question is whether benefits of this kind, such as Restricted Stock Units (RSUs), are subject to social security contributions in Belgium.