Part of a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective. From a Belgian perspective, no specific transfer pricing rules apply to transactions involving low-tax jurisdictions. This article considers the general tax provisions that may be applicable in cases of artificial profit shifting, namely the rules regarding the business purpose test, non-enforceable asset transfers and so-called presumptions of sham.