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 The first draft guidance and call for input dates back from late 2020.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
OECD issues a new package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 18 December 2023, the OECD released the third package of Administrative Guidance. This third package follows the Administrative Guidance released in February and July. This guidance provides welcome clarification to the Pillar 2 rules, which will in many territories, including Belgium, come into force as from financial year 2024, The document addresses issues and
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
The General Court considers the Belgian Excess Profits Ruling to be unlawful State Aid
On 20 September 2023, the General Court of the European Union (GCEU) ruled for the second time in the case of the Belgian Excess Profits Ruling (Belgian EPR) (Judgement of the General Court, 20 September 2023, in case T-131/16 RENV). Contrary to its first decision in 2019 on EPR as a “scheme”, it now confirmed
