Bram Markey is a Tax Director and leads PwC’s Tax Controversy Management practice in Belgium.
He advises Belgian and foreign headquartered groups on transfer pricing and international tax matters in an increasingly sensitive, transparent and complex tax environment. Bram looks at the sustainability of tax strategies given the viral spread of anti-tax avoidance rules, BEPS measures and proliferation of unilateral legislation.
Bram has solid credentials in finding solutions for tax controversy issues at all stages of the dispute lifecycle. He has developed significant expertise and insights on how to deal with multilateral tax audits and international exchange of information in practice. He successfully completed several milestone multilateral tax audit cases in Belgium and other EU countries.
Bram has captive working relationships with all bodies of the tax administration (field inspectors, central services, APA commissioners, competent authorities, etc) in view of efficient dispute prevention and resolution. This includes negotiating unilateral and bilateral APAs, tax audit settlements, administrative appeals as well as assistance with mutual agreement procedures and procedures under the EU Arbitration Convention. His mindset is always to find solutions in your interest as early as possible whilst at the same time safeguarding fundamental taxpayer (defense) rights.
Bram co-authored various articles and publications and is a guest lecturer at the Fiscale Hogeschool in Brussels and the University of Ghent.
PwC’s dedicated Tax Controversy Management practice is a multidisciplinary team that investigates transactions and potential issues in a holistic way. The team applies technology-enabled risk screenings and data analytics to prevent or help resolve tax controversies. There are experts that assist with the development and implementation of tax control frameworks. The cooperation with the tax litigation team at PwC Legal ensures that your rights are respected and that court proceedings can be pursued when needed.
