Transfer Pricing Audits in Belgium: Controversial Outcome?

This article analyses the application of article 207 of the Belgian Income Tax Code, which contains an anti-abuse provision, in a cross-border situation. It describes the utilization of article 207 by means of five examples and sets forth the legal framework. Next, a series of research questions is discussed concerning the position of the Belgian tax authorities and whether the anti-abuse provision is in line with both Belgian and international legal principles.