The Profit Split Method across Jurisdictions – Report on Belgium

Belgium adopts a pragmatic approach to the profit split method (PSM), closely following the OECD Transfer Pricing Guidelines and accepting its use where it appropriately reflects the economic reality of highly integrated business models. Both APA practice and case law provide valuable guidance on the method’s application and confirm the Belgian tax authorities’ burden of proof when challenging the taxpayer’s chosen methodology. This article is part of a special issue of the International Transfer Pricing Journal on the application of the PSM across jurisdictions. The other articles include the General Report and contributions on France, Germany, Ireland, Italy, Korea, the Netherlands, Portugal, Spain and the United States.

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Publication Details

Journal
International Transfer Pricing Journal
Published
2026-08-26
DOI
https://doi.org/10.59403/2mrzaz0
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
0.00
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article

The Profit Split Method across Jurisdictions – Report on Belgium

Aldo Engels
International Transfer Pricing Journal
Taxation and Legal Issues
article

The Profit Split Method across Jurisdictions – Report on Belgium

Aldo Engels
article en

Abstract

Belgium adopts a pragmatic approach to the profit split method (PSM), closely following the OECD Transfer Pricing Guidelines and accepting its use where it appropriately reflects the economic reality of highly integrated business models. Both APA practice and case law provide valuable guidance on the method’s application and confirm the Belgian tax authorities’ burden of proof when challenging the taxpayer’s chosen methodology. This article is part of a special issue of the International Transfer Pricing Journal on the application of the PSM across jurisdictions. The other articles include the General Report and contributions on France, Germany, Ireland, Italy, Korea, the Netherlands, Portugal, Spain and the United States.

International Transfer Pricing JournalVol. 33(4a)
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Openalex Percentile: Top 4%
Taxation and Legal Issues
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