Le rôle de l'auditeur externe face aux risques fiscaux liés aux prix de transfert des multinationales en Belgique : entre perception et réalité, une étude qualitative

Abstract

This thesis examines the role of the external auditor in the management of transfer pricing tax risks within multinational companies operating in Belgium. Based on a qualitative methodology relying on semi-structured interviews conducted with external auditors, tax experts and representatives of the tax administration, the research explores both the perception and the practical reality of the auditor’s involvement in transfer pricing matters. The findings suggest that external auditors contribute indirectly to the supervision of tax risks by reinforcing documentary and financial discipline through risk identification, documentation review and the promotion of more prudent tax positions, although their intervention remains limited by the scope of the audit mission.

The study highlights that transactions involving intangible assets and intra-group financing constitute particularly sensitive areas due to valuation difficulties, the absence of reliable comparables and the complexity of assessing economic substance. It also reveals a significant gap between the perception of the external auditor’s role among private-sector actors and that of the tax administration. While auditors and tax experts consider external audit as a useful mechanism supporting stronger transfer pricing documentation and greater prudence, tax authorities remain more critical regarding its practical impact on aggressive tax practices. Overall, the research suggests that external audit should be viewed less as an autonomous tax control mechanism than as an indirect mechanism of documentary and accounting discipline supporting the consistency of intra-group transactions.