Belgian transfer pricing update: New Royal Decree updates Local File form (275 LF)

On 19 December 2025, a new Royal Decree (dated 7 December 2025) was published in the Belgian Official Gazette. This decree introduces a small but important adjustment to the documentation requirements for the local file form (Form 275 LF).

While the previous Royal Decree of June 2024 announced more stringent reporting requirements (reference is made to previous newsletter), this new decree reverses the mandatory upload of transfer pricing agreements and transfer pricing studies.

Key changes for the Local File form (275 LF) (applicable for financial years starting on or after 1 January 2025)

It is no longer mandatory to attach the transfer price methodology or principle, and/or the framework agreement or model contract, and/or the transfer price study as a readable PDF when filing the Local File form. You may still do so optionally to provide context, but the strict obligation has been removed.

Please note that for specific documents such as Cost Contribution Agreements (CCAs), Advance Pricing Arrangements (APAs/rulings) and captive insurances the Belgian Tax Authorities still expect these to be appended to the form.

While the requirement to upload every agreement and transfer pricing study has been lifted, it remains vital to keep all documentation (agreements and studies) up to date and readily available internally.

Forvis Mazars can assist with determining your TP form obligations and with preparing and filing the necessary documents.