Géry Bombeke

Géry advises our clients on a broad range of corporate income tax issues, both international and domestic.

Géry's practice focuses on transfer pricing, where he assists clients with strategy, design, implementation and documentation. He also regularly negotiates unilateral and bilateral Advance Pricing Agreements (APA), and assists in transfer pricing audits and disputes, including mutual agreement procedures.

In addition to transfer pricing, Géry is also a tax specialist in corporate restructurings such as mergers and de-mergers, etc. where he assists our clients on pre- and post-acquisition restructurings, corporate simplifications, etc.

Being based in the centre of the EU, Géry centralizes and coordinates for most of his international clients the firm's tax assistance in the region.

• Design of European distribution models for a large number of clients and regular assistance in Belgian and foreign transfer pricing audits.

• Leading UK PDCF procedure for US specialty chemicals company with respect to sales and marketing remuneration for UK affiliate and subsequent mutual agreement procedure (MAP) between the US and the UK.

• Won litigation over a EUR 100 million withholding tax litigation with the Belgian tax authorities focused on alleged abuse and lack of beneficial ownership, with a full annulment of the tax assessment at administrative level.

• Assisting a US multinational in landmark court case on branch exemption profit at the level of Belgian head office of branches in the UAE.

• Design and implementation for financial industry client of complex cost contribution arrangement with respect to new platform software development.

• Successfully obtained first Belgian tax ruling on migration of foreign IP company to Belgium after introduction of step-up mechanism and in combination with the use of the Belgian innovation box regime.

• Advised a Belgian bank on tax and transfer pricing aspects of a EUR 5 billion loan securitization with a French affiliate and assisted in obtaining a transfer pricing ruling thereon.

• Successfully assisted US IT group in a transfer pricing audit on the exit of one of the largest Belgian finance companies.

• Led mutual agreement procedures for a US group between several European countries and the US, with the successful closing thereof within about one year from filing.

• Successfully obtained first Belgian tax ruling on tax neutrality for shareholders of company migration and merger which was implemented without accounting and tax neutrality.

• AmCham EU
• International Fiscal Association (IFA), Belgian branch
• Vlerick Management School Alumni