The Belgian authorities seized €65.2 million belonging to McKinsey at the request of the French National Financial Prosecutor’s Office (PNF).
Behind this spectacular amount lies a highly technical tax issue familiar to international groups: transfer pricing between related entities. A French case that also has concrete relevance for companies operating in Tunisia.
The Essentials
€65.2 million were seized in Belgium at the request of French justice.
This amount represents, according to the National Financial Prosecutor’s Office, 96% of the estimated tax loss at this stage.
The investigation concerns acts that could be classified as aggravated money laundering linked to aggravated tax fraud.
The French Senate had noted that the main French entities of McKinsey had paid no corporate income tax between 2011 and 2020, despite substantial activity in France.
The seizure is provisional: it does not constitute a conviction nor a definitive confiscation.
€65.2 million seized in Belgium
The seizure was carried out on 19 August 2026 as part of an international mutual legal assistance procedure. Its exact amount reaches €65,244,757.07.
The operation was made public on Friday, 4 September, in a joint press release signed by the French National Financial Prosecutor’s Office Pascal Prache and the Brussels King’s Prosecutor Julien Moinil.
According to the PNF, this sum represents 96% of the estimated tax loss at this stage of the investigation.
The preliminary inquiry was opened in March 2022 under the charge of “aggravated money laundering of aggravated tax fraud”. The investigations are now entrusted to the National Anti-Fraud Office.
Searches had notably been carried out in May 2022 at McKinsey France’s Paris offices. Witnesses and suspects have been questioned in 2025 and 2026.
What investigators are trying to establish
To understand the case, one must return to the report published in March 2022 by the French Senate’s inquiry commission dedicated to the influence of private consulting firms on public policy.
The senators noted that McKinsey’s main French entities paid no corporate income tax between 2011 and 2020, while the firm generated € 329 million in revenue in France in 2020 and employed around 600 employees.
The report did not challenge the fact that these companies were subject to tax in France. The question concerned the absence of actual corporate income tax payments during that period and the mechanisms that led to reducing their taxable income.
Transfer pricing at the heart of the case
The mechanism under review relies on transfer pricing, i.e., the prices charged for transactions between different companies within the same international group.
According to the Senate committee’s findings, McKinsey’s French entities paid sums to the American parent company based in Delaware. These intra-group charges related notably to various services or costs borne at the group level.
Recorded as expenses in the French entities, these sums reduced their taxable income in France. According to the Senate’s work, their level contributed to making the tax result zero or negative.
Transfer pricing does not mean fraud. International groups normally bill for services, licenses, technical assistance or other services among their subsidiaries. The tax question is whether the amounts charged reflect real services and comply with the so-called arm’s length principle, i.e., the terms that would have been applied between independent companies.
That is precisely one of the points the investigations are expected to clarify in the McKinsey case.
€65 million seized, but not yet confiscated
The seizure announced on 4 September marks an important step in the procedure, but it does not amount to a conviction nor a final confiscation.
The funds are currently blocked. Their final disposition will depend on the outcomes of the investigation and, where applicable, on subsequent judicial decisions.
It is also necessary to distinguish this tax procedure from other judicial investigations concerning the use of consulting firms and the conditions of some of their interventions around French electoral campaigns. The seizure announced on Friday concerns the tax investigation opened in 2022.
What McKinsey responds
During the controversy triggered in 2022, McKinsey stated that it complied with the French tax rules applicable to it.
The firm also said it paid €422 million in taxes and social security contributions in France during the period in question.
This response does not necessarily contradict the Senate’s finding. The €422 million cited by McKinsey covers different categories of taxes and social contributions, whereas the parliamentary work focused specifically on the corporate income tax paid by the main French entities.
The investigation will notably determine whether the tax practices examined complied with the applicable rules.
Asked on Friday about the seizure, McKinsey did not immediately respond to a comment request reported by Reuters.
A case born from the debate over consulting firms
The case took on a particular dimension in France because McKinsey advises governments and large companies on strategy, organization, transformation and risk management.
The Senate inquiry had shown that government and operator consulting expenditures had risen sharply. For the French ministries alone, they rose from €379.1 million in 2018 to €893.9 million in 2021.
The parliamentary inquiry had also studied the involvement of private consultants in several public policies, notably during the health crisis.
It is of course not illegal for a government to use a consulting firm. The debate concerns the conditions of this outsourcing: which missions should be entrusted to the private sector, at what cost, with what results and what level of transparency?
Why this case also interests Tunisian companies
The mechanism at the center of the McKinsey case is not unfamiliar to international groups operating in Tunisia. Transfer pricing is also a tax control issue for Tunisian companies carrying out significant transactions with related overseas subsidiaries.
Transfer pricing, what is it? It concerns the prices applied to transactions between companies within the same group. They are legal, but must reflect conditions comparable to those that would have been applied between independent companies. Their level can become a tax issue when they significantly reduce the taxable profit in a country.
Tunisia’s regulations have evolved in recent years. The 2019 Finance Law introduced new transfer pricing obligations. Article 15 of the 2021 Finance Law subsequently raised the threshold to 200 million dinars of annual turnover before tax for the main reporting and documentation obligations under this regime.
| Element | Threshold / rule |
|---|---|
| Turnover | At least 200 million dinars HT for the obligations under the regime |
| Transactions covered | Transactions with related resident enterprises or established abroad under the conditions provided by the regulation |
| Threshold by category | 100,000 dinars HT for the categories of transactions covered by the declaration and documentation obligations |
For a Tunisian subsidiary of an international group, management fees, IT services, royalties related to brand usage, technical assistance or other intragroup services can thus become central issues during a tax audit.
The issue is not only the amount billed. The company must be able to demonstrate the economic reality of the service, explain the method used to determine the price, and establish its compliance with the arm’s length principle.
For a Tunisian company
An intragroup invoice is not sufficient on its own. The service and its economic value must be explainable.
The price must be justifiable. The administration may examine the method used to reach the invoiced amount.
Documentation matters. The larger the intragroup operations, the more essential tracing and justification become.
There is also a separate country-by-country reporting regime for certain large multinational groups, with a consolidated turnover threshold of €1.636 billion.
And for administrations?
The other takeaway from the case concerns governments’ use of private consultants.
The issue may also be relevant for Tunisia, where public administrations, state-owned enterprises and programs financed with support from international partners regularly rely on consultants or study offices for strategy, transformation, digitization or technical assistance missions.
The French debate thus raises a broader question: which strategic capabilities should a state keep in-house, which can be outsourced, and how should the real usefulness of purchased services be measured?
An investigation that remains open
The €65.2 million seizure is a landmark step because, according to the PNF, it corresponds to nearly the entire currently estimated tax loss. It does not, however, settle the case.
Investigators still must determine whether the practices under review exceeded what the law allows and whether the elements constituting the offenses under investigation are present.
The National Financial Prosecutor’s Office states that the investigations are ongoing. Public sources consulted as of 4 September do not report any indictments in this tax procedure.
Main sources: joint press releases by the French and Belgian prosecutors on 4 September 2026, the French Senate inquiry commission’s work on consulting firms, public statements by McKinsey France, and Tunisian transfer pricing regulations.
