Belgian entities of foreign- or Belgian-headquartered multinational groups with annual revenues exceeding 50 million euros need to assess whether they will be subject to the transfer pricing documentation obligations that will be introduced soon. Given the increased scrutiny, it’s also imperative to check the consistency of transfer pricing arrangements with actual conduct.
Three layers of transfer pricing documentation are being introduced in Belgium:
The OECD’s country-by-country reporting;
A Masterfile covering information relevant to the entire group of companies (subject to the aforementioned 50 million euro threshold);
A Local File and tax return form including detailed information about an individual entity’s inter-company transactions (subject to the aforementioned 50 million euro threshold).
More information can be found here.