Belgium has published the Law of 2 May 2019, which transposes Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union.

The directive lays down rules on a mechanism to resolve disputes between Member States when those disputes arise due to a mismatch in national rules or different interpretations of a bilateral tax treaty with regards transfer pricing arrangements. Under the directive, companies and individuals can make a complaint under the new procedure as from 1 July 2019 for (cross-border) tax disputes concerning income or capital related to a taxable period commencing on or after 1 January 2018.