Ask a question
1000 characters left
> News
> New wave of transfer pricing audits

New wave of transfer pricing audits

The new 2021 transfer pricing (TP) audit wave has been launched this week.

Below, some ‘Must-Knows’ relating to TP audits:


  • The TP audit selection process often occurs via a software platform.
    Some typical red flags are business restructurings, IP transfers, missing TP documentation, steady cash pool positions, volatile sales or operating margins or material amount of losses carried forward.
  • The TP audit squad has been substantially strengthened during previous years and also provides technical support if TP issues are detected during standard corporate tax audits.
  • The TP audit procedure typically lasts between 6 to 18 months and starts with a “standard” audit questionnaire.
  • The pre-filing audit (virtual) meeting is highly advisable as it allows to limit the scope of the questionnaire by targeting certain questions. It has to be requested within 10 days.
  • Since tax year 2019, the ‘cash for tax-audit measure’ aims at refusing the use of tax attributes against tax & TP adjustments if a tax penalty of minimum 10% is imposed. Hence, even companies with tax losses could face direct cash out.

In order to avoid a long-lasting procedure as well as adjustments that could potentially lead to double taxation, it is of utmost importance to clearly outline the strategy to be adopted at the very beginning of the audit process. Note that in case a TP audit leads to double taxation, a mutual agreement procedure (‘MAP’) should be considered.

Generally speaking, it is recommended to have an accurate and updated TP documentation available justifying that the TP policies are at arm’s length.

Do not hesitate to call upon our team to assist you in this process.

Nicolas Bisschop

Tax partner

+32 (0)476 98 72 16


Our local offices

With over ten offices in Belgium and the Grand Duchy of Luxembourg, thg is well-established. This territorial coverage ensures a maximum of trust and efficiency. Find your local office!

Our management

The managers of thg have deliberately opted for close-to-the-customer service capabilities. That’s why we have a wide network of offices located in the main cities of the French- and German-speaking part of Belgium as well as in the Grand Duchy of Luxembourg. Each office can leverage upon internal and external experts in all areas of modern company management. Our management is at the customer's side.

Our clients
thg is a medium-sized accounting and tax firm serving more than 2,500 clients locally and internationally. Are you a free-lancer, at the head of a start-up or an executive of a company active on the domestic or international market? At thg, we understand your business issues and share your daily reality, whatever it may be. Whether they are big or small, local or international - we serve our customers with care and foresight.
Our values, our philosophy
At thg, client satisfaction is always our ultimate goal. We analyse our client's situation and help solving their business issues with added-value advise tailored to each specific situation. Our motivation is to provide you high quality services and to establish a reliable relationship based on respect and trust. With caution and foresight, we always have an eye on your goals.
A success story since 1983
Joseph Faymonville created his fiduciary in 1983 in his region of origin, on the border between Belgium, the Grand Duchy of Luxembourg and Germany. Today thg has more than 150 highly qualified employees and about 20 external partners. We are established in all the big cities of Wallonia as well as in the Grand Duchy of Luxembourg. 2500 clients benefit from our wide range of services. More about our history.