Doing business internationally creates opportunities, but it also brings increasingly complex tax challenges. Companies face transfer pricing documentation requirements, international group structures, withholding taxes, permanent establishments, tax reporting obligations and growing cooperation between tax authorities worldwide.

At PKF BOFIDI, we help companies manage international taxation not only correctly, but strategically. Our specialists combine technical expertise with a pragmatic approach, ensuring that international tax rules align with the reality of your business.

Whether you are a Belgian company with operations abroad, an international group with entities in Belgium, or a fast-growing business expanding across borders, we help you operate internationally with confidence.

Why international taxation deserves more attention than you might think

Tax authorities worldwide are paying increasing attention to cross-border transactions, profit allocation within international groups and transfer pricing. International information exchange, stricter documentation requirements and coordinated audits mean that companies must be able to substantiate their tax position more thoroughly than ever.

Inadequately documented transfer pricing, the incorrect application of a double tax treaty or an unidentified permanent establishment can lead to double taxation, tax increases, penalties and lengthy discussions with tax authorities.

At the same time, a well-developed international tax strategy creates opportunities: greater tax certainty, lower risks when expanding internationally, more efficient group structures and better preparation for audits.

Our International Tax & Transfer Pricing services

Transfer pricing advice and documentation

Transfer pricing is now one of the key tax considerations for international companies. We help you structure, document and defend transactions between associated enterprises correctly.

Our support includes transfer pricing analyses, benchmarking studies, intercompany agreements, financing structures, DEMPE analyses, transfer pricing policies, Master Files, Local Files and Country-by-Country Reporting.

Our goal is clear: to develop a transfer pricing policy that is not only defensible from a tax perspective, but also remains practical for finance, tax and management teams.

International tax advice that grows with your business

International transactions often have tax consequences in several countries at once. That is why we advise companies on specific transactions, strategic choices and complex international tax matters.

This includes international group structures, cross-border reorganisations, mergers and demergers, double tax treaties, withholding taxes on dividends, interest and royalties, international financing structures, intellectual property, innovation, Pillar Two (global minimum tax) and new developments in international taxation.

Our advice always starts from one principle: organising your international activities in a tax-compliant way without losing sight of commercial reality.

Permanent establishments and international presence

When companies develop activities outside their home country, the question often arises whether a taxable permanent establishment has been created.

We help companies assess permanent establishment risks, apply double tax treaties, meet registration and compliance obligations, allocate profits to permanent establishments and document the profit allocation methods used.

International projects, local representatives, employees working abroad for extended periods or cross-border management activities may, in certain circumstances, create a taxable permanent establishment. A timely analysis helps avoid unexpected taxation, double taxation and additional compliance obligations.

For questions concerning international employment, expatriate tax regimes, split payrolls, social security, immigration and tax residence, we refer you to our specialised services through MobilityToBelgium, where tax, payroll, social security and immigration matters are handled in an integrated way.

Worry-free international tax compliance

International activities often entail additional documentation and reporting obligations. We support companies with transfer pricing documentation, DAC6 reporting, Country-by-Country Reporting, Pillar Two compliance and reporting, foreign tax return obligations, tax registrations and international compliance projects.

You can rely on a tailored solution, ranging from a targeted review to the coordination of international compliance obligations across several countries. This allows you to stay focused on your business while we ensure tax consistency and follow-up.

Support during tax audits and disputes

Transfer pricing and international transactions are now among the main audit priorities of tax authorities.

We help you compile documentation, substantiate positions and manage discussions with tax authorities professionally. Our support includes transfer pricing audits, requests for information, rulings, Mutual Agreement Procedures (MAP) and double taxation disputes.

When should you involve us?

• Your business is expanding internationally.
• You have transactions between associated enterprises.
• You are required to prepare a Master File, Local File or Country-by-Country Report, or you fall within the scope of the global minimum tax (Pillar Two).
• You want certainty about your transfer pricing policy.
• You operate in several countries.
• You are unsure whether a permanent establishment exists.
• You face withholding taxes or double taxation.
• You are preparing an international reorganisation or acquisition.
• You receive questions from a tax authority about transfer pricing or international taxation.
• You want to identify and manage international tax risks in good time.

Our approach: clear, practical and international

1. We understand your business. We do not start with tax rules, but with your business, activities, value chain and international ambitions.
2. We identify risks and opportunities. We determine where international tax risks arise and where optimisation is possible.
3. We turn advice into action. No theoretical report that disappears into a drawer, but concrete recommendations and solutions tailored to the reality of your business.
4. We remain involved. International taxation is constantly evolving. We monitor changes, make adjustments where necessary and support your business as it continues to grow and expand internationally.

Why PKF BOFIDI?

PKF BOFIDI is the trusted adviser for ambitious entrepreneurs. We combine specialised expertise in international taxation and transfer pricing with broad support in accountancy, tax, legal, audit, payroll, corporate finance and business advisory. This means we do not view international tax matters in isolation, but as part of your entire business.

And when your business expands across borders, we can draw on the global PKF network to address foreign tax matters efficiently and in a coordinated way.