Belgium Transfer Pricing Documentation Requirements
Belgium is a filing jurisdiction. Entities above its size thresholds must lodge a Master File form and a Local File form rather than simply hold documentation on request, with the Master File due twelve months after the group year-end and the Local File filed with the corporate tax return.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Form 275.MF
Required | One of: operating & financial income > EUR 50m, balance sheet > EUR 1bn, or > 100 FTE | 12 months after group fiscal year-end | Submission deadline The documentation must be filed with the tax authority by the date shown. | NL / FR / EN | Yes (EUR 1,250 to EUR 25,000, escalating with repeat infringements) |
Local File Form 275.LF
Required | Same thresholds as the Master File; detailed Part II above EUR 1m of cross-border transactions | With the tax return | Submission deadline The documentation must be filed with the tax authority by the date shown. | NL / FR / EN | Yes (EUR 1,250 to EUR 25,000, escalating with repeat infringements) |
CbC report Form 275.CBC
Required | Group revenue ≥ EUR 750m | 12 months after group fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Belgium deadline
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Scope of the documentation obligation
A Belgian company or permanent establishment is brought within the documentation regime where, on its standalone financial statements for the preceding year, it exceeds any one of three thresholds: a sum of operating and financial income of EUR 50 million excluding non-recurring items, a balance sheet total of EUR 1 billion, or an annual average of 100 full-time employees. Meeting a single threshold is sufficient. The obligation is discharged by filing prescribed forms rather than by holding documentation for production on request.
Distinctive features of the Belgian regime
The defining feature of the Belgian regime is that documentation is filed on standardised forms with two distinct deadlines. The Master File form and the Country-by-Country form are due within twelve months of the last day of the group’s financial year, while the Local File form is filed together with the corporate tax return for the year concerned. The Local File form itself has a detailed second part that must be completed where a Belgian taxpayer’s cross-border transactions exceed EUR 1 million.
Penalties escalate with repetition. Infringements that do not arise from bad faith carry no penalty on the first occasion, then rise in steps to EUR 25,000 for subsequent infringements, with higher exposure where bad faith or an intention to evade tax is involved. Filing a Local File or Master File form also extends the assessment period: for financial years beginning on or after 1 January 2022, a taxpayer within the form-filing requirements is subject to a six-year assessment period rather than the standard three years.
Benchmarking and comparables
Where sufficient comparables cannot be found in the tested party’s own jurisdiction, the search may be widened to the closest comparable markets, and the Belgian administration accepts pan-European studies. Single-year testing is required. A full update of the comparability study is recommended every three years, with a yearly update of the results of the original study in the intervening years. The general three-year assessment period applies, extended to six years where the taxpayer is within the transfer pricing form-filing requirements.
Frequently asked questions
Do the Belgian Master File and Local File have the same filing deadline?
No. The Master File form and the Country-by-Country form are due within twelve months of the group year-end, while the Local File form is filed together with the corporate tax return.
Does filing transfer pricing forms affect the assessment period in Belgium?
Yes. For financial years beginning on or after 1 January 2022, a taxpayer required to file a Local File or Master File form is subject to a six-year assessment period instead of the standard three years.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.