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
Mid-summer tax update
As we reach mid-summer, it’s time to do a short wrap-up of some of the recent tax developments to keep you up to date in this ever-changing tax landscape. In this update we will cover the following topics: Council of Ministers accept the Belgian implementation of the Public CbCR Directive Belgian Parliament considers bill to
Filed your transfer pricing documentation in due time?
The Belgian Tax Administration (BTA) continues to send out letters to eligible taxpayers for missing/late filing of the mandatory transfer pricing documentation, as the case may be: The country-by-country report (art. 321/2 BITC), The country-by-country report notification (art. 321/3 BITC) The master file (art 321/4 BITC), The local file (art 321/5 BITC). For the first
