The DEMPE Concept and Its Role in Domestic Transfer Pricing Practice – Report on Belgium

This article explores how Belgium has integrated the OECD’s DEMPE framework into its domestic transfer pricing practice for intangibles. It examines the legal framework, documentation requirements, administrative guidance, APA practice and key case law, highlighting how Belgian tax authorities and courts apply DEMPE in audits, rulings and case law.This article is part of a special issue of the International Transfer Pricing Journal on the DEMPE concept in domestic transfer pricing practice. The other articles include the General Report and contributions on France, Germany, Ireland, Italy, Korea, Luxembourg, the Netherlands, Spain and the United States.