
Helena Caluwé
Senior Manager at PwC Belgium specializing in indirect tax, customs and international trade (CBAM and carbon taxation), and co-host of PwC's Tax Bites Podcast.
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Aug 25, 2026
CBAM and Transfer Pricing
9:16
9:37
10:13
10:47
15:14

Pieter DereHOST
Now, I'm just wondering what kind of information From a transpricing perspective, can you take into account to make that analysis? Helena, what kind of information, what facts should the tax people in the podcast here ask for to do that exercise? What's available?

Helena CaluwéGUEST
yeah i think it's it's very important to um to understand that not each cbm product is uh the same so we have a lot of different cost drivers um so with which products are in scope and one product within your um product portfolio, it can look like the same product, but actually have a different supplier or a different production installation.

Helena CaluwéGUEST
and information to share with the with the dp team the actual verified emissions available or are there default values being used for the specific product that you're looking at also is there a carbon price already paid in the country of origin that may reduce the cbm obligation and then who in the group has the ability to influence those variables.

Helena CaluwéGUEST
EU distributor, as I understand it from Joris, simply receives goods and access importer of records, but the non-EU principal chooses the supplier, controls the production footprints, negotiates the supply contracts, decides whether to invest in lower carbon inputs, then the distributor may have the legal filing obligation.

Pieter DereHOST
Okay, Helena, from where you look at it, do you recognize this, what yours is saying, this challenge?
CBAM Business impact
8:52
9:16
P
8:47PieterHOST
Can you elaborate a bit more on what kind of functions are involved here?

Helena CaluwéGUEST
So if we start with the procurement and the sourcing function, they are on the front line because they are sourcing the products.

Helena CaluwéGUEST
We also see that they have a role in collecting the embedded emissions data because they have that close relationship with the suppliers.
5 MINS LATER
P
14:47PieterHOST
What do you think, Helena?