New guidance for Belgian transfer pricing documentation and filing requirements

Local contact

EY Belgium Tax

3 Jul 2020
Subject Tax alert
Categories Transfer Pricing
Jurisdictions Belgium

Effective as of 1 January 2020.

On 30 June 2020, the Belgian Tax Authorities issued Circular Letter 2020/C/88 clarifying the transfer pricing documentation and filing requirements for Belgian tax payers. They are effective as of 1 January 2020.

Since 2016, Belgium has formal transfer pricing documentation requirements to submit the master file (Form 275.MF), local file (Form 275.LF), country-by-country reporting (Form 275.CBC) and the notification of country-by-country reporting (Form 275 CBCNOT) for qualifying multinational groups. This new Circular Letter provides detailed responses to 110 Frequently Asked Questions (FAQ) around: (i) the obligation to file and filing period; (ii) the thresholds; (iii) the application to non-profit entities; and (iv) specific issues and questions on the individual forms to file. The Circular expands and clarifies the FAQ responses previously provided by the Belgian tax authorities on 4 May 2018.

Given the upcoming filing date for some of these forms, please consult this new guidance and do not hesitate to reach out to our experts for further advice.

The updated FAQ responses can be consulted via this link.