Hello everyone. Welcome to PWC TaxBite podcast series. My name is Peter. I'm your host today, as in the previous episodes, of course, and I'm very happy to welcome three colleagues in my virtual recording studio. We have here Brecht and Veronique.

Brecht and An are trans-spressing experts with a focus on TCDR and

Veroique is part of our legal firm and is a legal expert but also with a focus on TCDR.

I invited Brecht and Veroenic to talk about the topic of today, which is

the Belgian trans-pricing audit landscape. So this is a podcast which continues the series of

podcasts we are doing on tax audits. So we're focusing on a number of topics specifically relevant for audits.

And today we focus on the transpricing audits in Belgium. We're going to talk about what is

changing in the Belgian landscape, what the focuses of these audits, what the struggles are

of taxpayers to deal with trans- transpressing audits in Belgium.

Now, to set the scene, my first question is for you, Brecht, because PWC and PWC Legal

published a news alert at the end of February, stating that the traditional large-scale

tax audit wave in February was over. Why did you publish this news alert?

Well, Peter, we wanted to share an update on three very important developments in the TP audit landscape.

So the first development indeed is that we no longer see that TP audits are launched all at once in one single big wave at the beginning of the year.

Because as you know in the past, it was a well-known practice that at the beginning of the year, mostly in February,

the big TP audit wave was launched. And sometimes there would even be a formal announcement of the wave

and which specific topics would be focused on as part of this wave.

And so over the years we saw a decline of this practice.

And recently we also received informal confirmation

that this is no longer an established practice.

We do still see an increase in audit activity in February and March, but this is mainly

linked to the way in which files are being selected and allocated within the tax administration.

...