Belgium publishes Public Country-by-Country Reporting form and definitive taxonomy
On 24 December 2025, the National Bank of Belgium (NBB) announced that the new definitive taxonomy including the Public Country-by-Country Reporting (pCbCR) model is accessible on the Central Balance Sheet Office’s website. This update follows the transposition of EU Directive 2021/2101 regarding pCbCR into Belgian law on 8 January 2024 and the Royal Decree on 18 June 2024. As a reminder, pCbCR obligations generally apply to
Belgium partially repeals previously introduced updates to the form 275LF
On 7 December 2025, Belgium issued a new Royal Decree reversing several amendments introduced to the Belgian transfer pricing documentation forms by the Royal Decree of 16 June 2024, prior to these changes taking actual effect. Belgium’s transfer pricing documentation regime consists of the Local File Form (275 LF) and Master File (275 MF). Entities belonging to multinational groups with consolidated gross revenue of EUR
Upcoming changes to the Belgian transfer pricing documentation forms
Transfer pricing documentation has become an integral part of the compliance obligations of Belgian entities since financial year 2016. A Belgian company (or a branch) that is a part of a multinational group will have to submit the form 275 LF (Local file) and the form 275 MF (Master file) in case one of the following
OECD issues a fourth package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 17 June 2024, the OECD released the fourth set of Administrative Guidance on GloBE rules, with the intention of clarifying the operation of these rules. This package follows the Administrative Guidance sets released in February, July and December last year. It is the first package of Administrative Guidance following the publication of the Consolidated
Royal Decree on Public Country by Country Reporting published
On 6 June 2024, the Royal Decree on public country by country reporting (PCbCR) was published in the Belgian official gazette (See also our earlier messages on the introduction of public country by country reporting in Belgium of 4 June 2021 and 17 November 2023). This Royal Decree modifies the Royal Decree of 29 April
New wave of Belgian transfer pricing audits
The Belgian tax authorities have recently initiated a new wave of transfer pricing audits. Many taxpayers have already or will soon receive an in-depth questionnaire requesting bulk taxpayer information in relation to their transfer pricing arrangements. This first request for information on intercompany transactions and the activities carried out by the Belgian company or branch
Circular letter relating to the settlement of cross-border tax disputes in the European Union
On 1 December 2023, the Belgian tax authorities issued a circular letter (2023/C/95) relating to the settlement of cross-border tax disputes in the European Union. This circular letter provides clarification to help overcome the difficulties that may arise in the interpretation or application of the law of 9 May 2019 implementing Council Directive (EU) 2017/1852
Draft law on public country-by-country reporting in parliament
Introduction In our previous newsflash regarding the public country-by-country reporting (PCbCR) directive, we informed you that EU member states must introduce the directive in their domestic legislation by 22 June 2023 at the latest. Belgian PCbCR draft law On 10 November 2023, the Belgian draft law was finally published. As per the draft text, companies
