Aldo Engels
Partner - Attorney at Law
Aldo Engels, attorney at law, is a member of the Loyens & Loeff Direct Tax Practice Group and heads the Transfer Pricing Team in Belgium.
Aldo advises on corporate and international tax matters, with a strong focus on transfer pricing. His counsel in transfer pricing includes strategic advice, documentation & pricing, negotiations with tax authorities, dispute resolution and litigation. He advises on business model design & conversion, restructurings & procurement models, permanent establishment issues and transactions involving intangibles. He has a strong passion for intra-group financing, including analysing and modelling optimal financing structures, loan pricing, cash pool models, and real estate financing.
Beyond transfer pricing, Aldo has extensive experience in investment structuring and withholding tax matters, tax treaty issues (including PE and MLI impact), Pillar II, restructuring & insolvency related tax matters as well as financial institutions & exchange of information mechanisms (FATCA & CRS). Finally, he regularly advises on the tax aspects of financing transactions, such as structured finance, syndicated loans, factoring/securitization, and capital markets transactions. Aldo is also recognised in his field of expertise by ITR and Leaders League.
Work highlights
Contributions
Memberships
Brussels Bar, 2012
Qualifications
Advanced Transfer Pricing course within the LL.M. (Adv.) Program in International Tax Law, ITC Leiden (The Netherlands), 2013
Master’s degree in Tax Law, Université libre de Bruxelles (Belgium), 2012
Master’s degree in Law, Katholieke Universiteit Leuven (Belgium), 2011
Publications
A. ENGELS, “Belgian Court Rejects Tax Authorities’ Use of Transfer Pricing Principles to Deny Deduction of Royalty for Tradename Use”, in International Transfer Pricing Journal (Ongoing 2025).
A. ENGELS, “The DEMPE Concept and Its Role in Domestic Transfer Pricing Practice – Report on Belgium”, in International Transfer Pricing Journal (2025).
A. ENGELS, “How the Forthcoming Tariffs Will Impact Transfer Pricing”, in Bloomberg – Tax Management International Journal (2025).
A. ENGELS, “US Tariffs: The EU Perspective”, in Tax Executives Institute (2025).
A. ENGELS, “Quand la fiscalité s’invite chez vous: votre domicile peut-il être un établissement stable?”, in Revue Générale de Fiscalité et de Comptabilité Pratique (2025).
A. ENGELS, “Transfer Pricing 2025 - Belgium – Law & Practice”, in Chambers Global Practice Guides (2025).
A. ENGELS, “Transfer Pricing 2025 - Belgium – Trends & Developments”, Chambers Global Practice Guides (2025).
A. ENGELS, “Profit Allocation to a Permanent Establishment – The Sour Taste of Apple”, in ACE Luxembourg (2024).
Aldo Engels
Partner - Attorney at Law
aldo.engels@loyensloeff.com
Brussels
Dutch, English, French
<p>Aldo Engels, attorney at law, is a member of the Loyens & Loeff Direct Tax Practice Group and heads the Transfer Pricing Team in Belgium. <br></p>
Aldo advises on corporate and international tax matters, with a strong focus on transfer pricing. His counsel in transfer pricing includes strategic advice, documentation & pricing, negotiations with tax authorities, dispute resolution and litigation. He advises on business model design & conversion, restructurings & procurement models, permanent establishment issues and transactions involving intangibles. He has a strong passion for intra-group financing, including analysing and modelling optimal financing structures, loan pricing, cash pool models, and real estate financing.
Beyond transfer pricing, Aldo has extensive experience in investment structuring and withholding tax matters, tax treaty issues (including PE and MLI impact), Pillar II, restructuring & insolvency related tax matters as well as financial institutions & exchange of information mechanisms (FATCA & CRS). Finally, he regularly advises on the tax aspects of financing transactions, such as structured finance, syndicated loans, factoring/securitization, and capital markets transactions. Aldo is also recognised in his field of expertise by ITR and Leaders League.