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.