Transfer Pricing 2025

BELGIUM Trends and Developments

Trends and Developments Contributed by: Aldo Engels, Emile Bauwens, Emma Parduyns and Vincenzo Vilardi Loyens & Loeff

Loyens & Loeff is a leading law firm and a le - gal and tax partner for clients doing business in or from the Netherlands, Belgium, Luxem - bourg and Switzerland. Its 1,000 advisers are based across its offices in the Benelux, Swit - zerland and other key financial centres around the world. Thanks to its full-service practice, sector-specific experience and thorough under - standing of the market, the firm’s advisers com - prehend exactly what clients need. The transfer pricing team consists of experts from various

tax areas, offering a fully integrated approach to transfer pricing matters. Expertise ranges from advice on strategy, documentation and inter - action with other tax and legal issues to nego - tiations with (international) tax authorities and dispute resolution. Given the ongoing actions taken by the G20, OECD (BEPS) and the EU, transfer pricing has become more important than ever, and Loyens & Loeff is well equipped to provide seamless service both on tax and on legal aspects.

Authors

Aldo Engels is an attorney-at- law, a member of the Loyens & Loeff Direct Tax Practice Group and leads the transfer pricing team in Belgium. He advises on matters related to corporate tax

Emile Bauwens is an attorney- at-law and a member of the Loyens & Loeff Direct Tax Practice Group and of the transfer pricing team in the firm’s Brussels office. He

law and international tax law, with a strong focus on transfer pricing, providing counsel on strategy, documentation and pricing, negotiations with tax authorities, dispute resolution and litigation. He advises on business model design and conversion, restructurings and procurement models, permanent establishment issues and transactions involving intangibles. He has a strong passion for intra-group financing, including setting up and modelling financing structures, loan pricing, cash pool models, and real estate financing.

advises on matters related to corporate tax law, international tax law and transfer pricing. His counsel work includes strategic advice, negotiations with tax authorities and dispute resolution. He advises on the setting up and conversion of business models, restructurings, intra-group financing and M&A transactions.

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