Transfer Pricing in Belgium, Luxembourg and The Netherlands

Highlights from each jurisdiction

Belgium

In recent years, transfer pricing has become a key focus area for the Belgian tax administration (BTA) and has gained increasing importance in Belgian tax practice. Our contribution covers legislative updates, Pillar Two, recent case law and more. In addition, Belgium also provides practical insights for taxpayers in the Law & Practice chapter, sharing in-depth guidance on domestic rules and procedures.

Luxembourg

While 2024 saw limited legislative changes, transfer pricing remains a hot topic in Luxembourg for both taxpayers and tax authorities, domestically, at EU level and internationally. Key topics covered in this contribution include a new Circular on interest rates on shareholders’ current account, Pillar Two, documentation and more.

The Netherlands

The transfer pricing landscape in the Netherlands underwent significant developments in 2024 and early 2025. Our article highlights clarification around the transfer pricing mismatch legislation, dispute resolution and prevention, relevant case law concerning business restructurings and shareholder loans, the implementation of Amount B, and more.

You can download all four chapters below.

Any further questions or in need of assistance after reading these contributions? Please contact a member of our Transfer Pricing team or your trusted Loyens & Loeff adviser.