Tax bites podcast – International Tax Strategy for 2026: Aligning global tax policy changes with business operations
This podcast covers key points from our 6 February 2026 international tax webinar, including the Side‑by‑Side Package, updates on trade and tariffs, work mobility, and changes to the OECD Commentary. We also discuss expectations for 2026. If you’re interested in learning more or accessing the full webinar recording, please contact one of the presenters. Listen here: https://www.pwc.be/en/services/tax-and-legal/tax-bites-podcast-series/episode-62-international-tax-strategy-for-2026-aligning-global-tax-policy-changes-with-business-operations.html About the speakers
Belgium issues administrative clarification regarding the new form 275 CBC NOT
On 27 January 2026, the Belgian tax administration released updated guidance on the interpretation of the amended Country-by-Country Notification (“CbC Notification”) requirements (Form 275 CBC NOT). This follows the introduction of the amended Form 275 CBC NOT earlier in 2024 (New Royal Decree of 16 June 2024). As a reminder, all Belgian constituent entities within multinational enterprise (MNE) groups must submit a CbC Notification if the MNE group is subject
Tax Bites Podcast – Inside the OECD Pillar 2 Side-by-Side package: Key features and insights
This podcast episode provides an overview of the Pillar 2 Side-by-Side agreement and its key features. We discuss the main points of the newly introduced safe harbors and highlight what listeners should watch for in the (near) future. Tune in for practical insights and essential takeaways on this important topic. Are you interested in learning more about the Side-by-Side package? Sign
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
The OECD released a new package of Pillar 2 documents
On 15 January 2025, the OECD released a new package of documents including (i) the central record of legislation with qualified domestic rules, (ii) additional Administrative Guidance, and (iii) an updated version of the GloBE Information Return (GIR), the XML scheme/user guide and a Multilateral Competent Authority Agreement. List of legislations with a Transitional Qualified
How key interest rate cuts and stabilising inflation might impact your transfer pricing policy
The past few years the financial markets have been characterised by a significant increase in interest rates battling the surge in inflation throughout the world. Since the arm’s length principle requires intercompany transactions to appropriately reflect current market conditions, these exogenous elements have led companies to update their financing policies and more specifically their transfer
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
OECD Published Guidance on Amount B
On 19 February 2024, the OECD published a report which aims to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities (the Report) (also known as Amount B under Pillar One). The first draft guidance and call for input dates back from late 2020. Quite some time
