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PwC's Tax Bites Podcast

Amended penalty regime for first offence

PwC's Tax Bites Podcast

PwC Belgium

Bites, Business, Workforce, Legal, Tax

5.01 Ratings

🗓️ 12 September 2025

⏱️ 19 minutes

🧾️ Download transcript

Summary

With this podcast we kick off a series of podcasts on topics related to tax audits. In this first podcast we discuss the recent amendment to the penalty regime applicable to a first offence. Pieter interrogates his guests on the implications of this amendment and what this means for the taxpayer in practice: can we really say that the taxpayer has the right to make a mistake? Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

Transcript

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0:00.0

Hello everyone. My name is Peter Drey and I welcome you to the TaxBite podcast series.

0:11.4

This is a special Tax Bite podcast because we make a sub-series of podcasts regarding tax disputes,

0:20.5

mitigation and how to deal with them.

0:24.2

And in this sub-series of the podcast, we will deal with several topics all relating to this

0:29.8

overall topic of tax disputes.

0:31.7

We see it's much more important.

0:34.3

We see more and more disputes, so it's good to spend some time on this.

0:38.8

This first episode, and I'm very happy to welcome Vironique de Brabantler and Gottjeval,

0:44.4

to my virtual recording studio. We will talk about tax penalties, and in particular,

0:49.8

some changes we see in the legislation in Belgium regarding the application of tax penalties

0:55.7

in tax audits.

0:57.8

Veronique and Gauthier are both lawyers in PWC Legal, the affiliated law firm of PWC,

1:04.0

and Veronique is heading up the team in PWC legal that is specialized in tax procedures

1:08.9

and dispute resolutions.

1:11.1

So I suggest we just kick it off.

1:15.5

Welcome, Veronique Engotier.

1:17.8

And, yeah, maybe just to start, it was mentioned in the Belgian government agreement

1:22.8

and the new program law, which was in July of this year,

1:28.3

yeah, published, there is a new principle and a new penalty regime.

1:32.3

And the principle introduced is that taxpayers who act in good faith

1:37.3

will no longer have to pay penalties in a first infringement.

1:42.3

So is this an actual change that you see,

...

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