PwC's Tax Bites Podcast

We are facing times of unprecedented changes and challenges. Taxation has been closely connected to geopolitical developments in the past century, given the connection between tax revenues and public expenditure. In this podcast series we reflect on the relevance of the geopolitical developments in view of tax policy. We provide an insight into the main tax policy developments that you should be aware of. Our EU tax bites focus on direct tax developments in the EU and beyond.

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PwC's Tax Bites Podcast

CBAM and Transfer Pricing

August 25, 2026 • PwC Belgium

0:00 | 34:09

CBAM is no longer just a border compliance topic it is becoming a real transfer pricing issue for multinational groups. As carbon costs enter cross-border value chains, companies need to ask where those costs should land, i.e., with the importer, the principal, the manufacturer, or another group entity.

In this episode, Helena Caluwé, Pieter Dere and Joris Reijnierse explore:

How CBAM affects function and risk analysis, intercompany pricing, benchmarking, year-end adjustments and transfer pricing documentation;

Why consistency between CBAM data, customer pricing, ESG reporting and transfer pricing documentation will be critical given that tax authorities’ scrutiny in this area is envisaged.

Overall, a practical conversation for CFOs, tax directors and transfer pricing teams preparing for the financial and tax impact of CBAM.

Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites