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Belgium, known for its EU influence and cultural exports, is now turning heads in the transfer pricing (TP) world. In 2024, the Belgian tax authority (BTA) collected EUR 1.17 billion through TP assessments, significantly outperforming peers in the OECD world.
This remarkable result isn’t by accident. Belgium’s tax authority has invested heavily in data collection, automation, and audit readiness, making it a clear frontrunner in data-driven TP enforcement. But what does this mean for TP advisors, and how can firms prepare? The answer increasingly lies in tools like Reptune, which automate the structured documentation that regulators like the BTA now expect.
Belgium’s TP documentation requirements go well beyond the OECD BEPS Action 13 framework. The Local File (Form 275 LF) is not a narrative document but an XML-based form filled with:
When submitted with the annual Corporate Income Tax return, these forms provide the tax authority with a ready-to-analyze dataset. The Master File (Form 275 MF) is also required, and its proactive submission ensures the BTA always has a full view of a multinational’s global structure and transfer pricing logic.
Such transparency enables data-driven risk assessments that surpass many other tax administrations in efficiency and accuracy.
KPMG reports that the BTA is actively leveraging data mining tools to flag high-risk taxpayers based on the data collected in these XML forms. Their audit selection process is no longer random—it’s surgical.
🔍 Risk scoring models identify anomalies in intercompany margins
🔍 Comparability checks highlight inconsistencies with peer benchmarks
🔍 Quantitative red flags trigger deep-dive audits
This modern approach ensures fewer resources are wasted and that audits are more likely to result in substantial adjustments. This is especially evidenced by the record EUR 1.17 billion in 2024 collections.
In this new environment, advisory firms and in-house tax teams need to mirror the sophistication of tax authorities like the BTA. That’s where Reptune comes in.
Reptune automates the entire transfer pricing documentation cycle, with features built for modern regulatory demands:
✅ Local File and Master File templates – Standardized templates updated for OECD and local variations
✅ Quantitative Data Integration – Uploading financial data in a structured way using pre-determined consistent templates
✅ Narrative Add-On Capability – Add relevant commentary wherever needed for flagged transactions
✅ Real-Time Risk Indicators – Monitor for anomalies before authorities do
For advisory firms serving multinationals, Reptune is the bridge between traditional narrative-heavy documentation and the structured, data-rich future.
With so much emphasis on structured data, some wonder if narrative documentation is becoming obsolete. The short answer is: not entirely.
While XML submissions and quantitative disclosures are driving initial audit targeting, narratives are still needed for:
This is especially important if a tax authority questions your submission or demands a deeper dive. In those cases, a clear and concise narrative can prevent prolonged disputes.
Reptune supports both, automating structured files while keeping narrative modules available for high-risk situations.
Belgium’s data-first approach to transfer pricing audits is more than just a national story—it may be a preview of the global future. With lots of quantitative information available and tax authorities adopting data mining tools, firms must evolve fast.
Automation tools like Reptune offer a way forward. It empowers teams to produce compliant, audit-ready documentation with minimal manual effort. The result? Fewer errors, faster filings, and more confidence when facing audits in Belgium. Or anywhere else.
Is your documentation strategy ready for Belgium-style audits? Let Reptune help you lead the change. Book a demo today.
