Key deadlines and enhanced Belgian TP requirements for FY25 (AY26)

Belgian transfer pricing documentation obligations

Belgian transfer pricing documentation obligations apply to Belgian entities and Belgian permanent establishments of multinational groups when at least one of the following thresholds is exceeded, based on the statutory annual accounts for the financial year preceding the last closed financial year:

• Operational and financial income of at least €50 million, excluding non-recurring income
• A balance sheet total of at least €1 billion
• An annual average workforce of at least 100 full-time equivalents

If any of these thresholds is exceeded, Form 275 LF (Local File Form) and Form 275 MF (Master File Form) must be prepared and submitted.

It is also important to consider the updated Belgian transfer pricing documentation requirements that apply to financial years starting on or after 1 January 2025. As these requirements are now more stringent and demanding, additional work may be needed to maintain compliance with the Belgian transfer pricing requirements.
Please see the attached document for further details.

In addition, Belgian entities belonging to groups within the scope of Country-by-Country (“CbC”) reporting should verify whether a Form 275 CBC NOT filing is required. Under the revised requirements, a filing is now mandatory not only for initial filings or amendments, but also when an existing notification is terminated, for example in the event of a dissolution or acquisition by another multinational group.

These OECD CbC requirements should not be confused with the separate and more recent Public CbC reporting obligation. More information on Public CbC reporting can be found in our previous publication: Public Country-by-Country Reporting: technical update - Forvis Mazars.

Key deadlines – concentration of compliance obligations (!)

It is important to highlight that the filing deadline for the Belgian Local File Form (Form 275 LF) is set at 30 September 2026 for calendar-year taxpayers. This date coincides with two other key compliance deadlines for many Belgian entities, namely:

• the statutory deadline for filing the Belgian corporate income tax return (Biztax), and
• the first filing deadline for the Belgian QDMTT return applicable to in-scope Belgian constituent entities

As a result, taxpayers may face a significant concentration of compliance obligations within a very short timeframe.

Given this convergence of deadlines, we strongly recommend that companies start preparing and populating the Local File Form without delay. Early preparation will help ensure data consistency across filings, allow sufficient time for internal validation, and mitigate the risk of last-minute issues or inconsistencies between transfer pricing documentation, corporate income tax reporting, and Pillar 2 disclosures.

How we can help?

Forvis Mazars can support you in assessing your filing obligations, preparing the necessary Belgian forms and reviewing or updating your transfer pricing documentation where needed.