On 22 May 2026, the Belgian tax administration released additional guidance on the interpretation of the Country-by-Country Notification requirements (Form 275 CBC NOT), adding a third specific situation to the previously issued administrative clarification of 27 January 2026.
As a reminder, the Belgian tax administration had already clarified how the option ‘termination of your notification obligation’ should be applied in two specific scenarios: (i) where a Belgian entity changes MNE group, and (ii) where the consolidated revenue of the MNE group falls below the EUR 750 million threshold. For further background, see our earlier newsflash ‘Belgium issues administrative clarification regarding the new form 275 CBC NOT‘. The newly published guidance now adds a third scenario: the liquidation of a Belgian entity.
New scenario: Termination due to liquidation of a Belgian entity
The Belgian tax administration has clarified that the liquidation of a Belgian entity does not automatically result in the cessation of Country-by-Country Reporting (CbCR) obligations in Belgium. In accordance with Article 208 of the Belgian Income Tax Code 1992, a company in liquidation continues to exist for tax purposes throughout the liquidation process and may, where applicable, still be considered a constituent entity of a multinational group for the relevant financial year.
Since the end of the CbC reporting obligation cannot be automatically derived from the publication of the liquidation in the Crossroads Bank for Enterprises (KBO), the Belgian constituent entity concerned must still actively file a CbC Notification, selecting the option “Termination of your notification obligation, due to no longer being a member of the MNE group.” Groups with Belgian entities in liquidation should therefore ensure that this termination notification is filed as part of their internal liquidation process.
Important reminder: use of the ‘modification’ option
The tax administration further reiterates that the option ‘modification of a previous notification’ may not be used in the scenario described above, nor in the two scenarios clarified in the additional guidance issued on 27 January 2026 (change of MNE group and falling below the EUR 750 million revenue threshold). This option is strictly reserved for cases where the Belgian constituent entity remains within the same MNE group and continues to be subject to the reporting obligation, but where certain information has changed, such as the address, name, or identity of the reporting entity.
How can PwC Belgium support?
For further information on the potential impact of this additional guidance, or for assistance with filing a (revised) CbC Notification, please contact Carla Buyens or your regular PwC contact.
Carla Buyens Director Tel: +32 493 24 06 80
