- Publication of New Decrees: On 15 July 2024, Belgium published three royal decrees amending transfer pricing documentation requirements for financial years starting on or after 1 January 2025, replacing the decrees from 2016.
- Enhanced Reporting Requirements: The new decrees require more detailed reporting and transfer pricing analyses in forms such as the master file (Form 275 MF), local file (Form 275 LF), and CbC reporting notification (Form 275 CBC NOT) to increase tax transparency and ensure compliance.
- Updated Form 275 LF: Changes include mandatory reporting of intercompany transactions per country code and the inclusion of tax identification numbers for key competitors and permanent establishments, along with a requirement to append transfer pricing documentation.
- Expanded Explanatory Notes for Form 275 MF: Additional information and analysis are now required, including detailed descriptions of value chain analysis, intangibles management, and financial transactions in accordance with the OECD Transfer Pricing Guidelines.
- Clarifications for Form 275 CBC NOT: The form now allows for clear distinctions between initial notifications, modifications, and terminations of reporting obligations, addressing past shortcomings and streamlining the notification process for multinational enterprises.
Source Deloitte
