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ARTICLE · 25 OCTOBER 2024

Tax: News On Transfer Pricing Documentation

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The Royal Decrees of 16 June 2024 (replacing the Royal Decrees of 28 October 2016) amend transfer pricing reporting rules (Dutch/French).

BelgiumTax
Geoffroy Galéa
Geoffroy Galéa
Stefanie Hardy
Stefanie Hardy

1. Belgian Transfer Pricing Forms: Amended as from January 2025

The Royal Decrees of 16 June 2024 (replacing the Royal Decrees of 28 October 2016) amend transfer pricing reporting rules (Dutch/French). Amendments will be in application for financial years beginning on or after 1 January 2025.

Background

By Royal Decrees of 28 October 2016, Belgium introduced the three-tier mandatory transfer pricing reporting structure composed of three forms:

  1. a Master File form (275.MF);
  2. a Local File form (275.LF); and
  3. a Country-by-country report (275.CBC) or notification form (275.CBC.NOT).

As a reminder, Belgian entities/branches of multinational groups must file Master File and Local File forms when one of the following thresholds is exceeded (during the previous financial year):

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