Filed your transfer pricing documentation in due time?


The Belgian Tax Administration (BTA) has started to send out the letters to eligible taxpayers for missing/late filing of 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 infringement without the intent to evade taxes, the administrative penalty is set at 0 (zero) euro.  However, as from the second infringement, the penalties for non or incomplete filing will vary between 1,250 EUR to 25,000 euro.  Further, other administrative measures such as the reversal of the burden of proof or ex officio assessments are possible in case of late or non filing of the transfer pricing documentation.  

We remind you therefore to file to transfer pricing documentation in due time to avoid the penalties and any other administrative measure. The upcoming deadline for Assessment Year 2022 is October 17th, 2022 for the local file.

The BTA allows that arguments are brought forward on why the transfer pricing documentation was not or lately filed.  

In case of questions, please contact Carla Buyens (, Chiara Storms (, Stefaan De Baets ( or your usual PWC team.