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 to Country-by-Country Reporting (“CbCR”) requirements. Annual notifications are no longer required (since 2019) ; instead, a CbC Notification should be filed only when there are changes to the information reported compared to the previous filing (e.g. changes to the address).
The revised Form 275 CBC NOT, applicable as from accounting years starting on or after 1 January 2025, requires taxpayers to indicate whether their submission constitutes:
- a first notification;
- a modification of a previous notification; or
- a termination of the notification obligation, due to no longer being part of the MNE group.
In practice, especially regarding the termination criterion, it was unclear when a CbC Notification was required. To bring more clarity, the tax administration has issued explicit guidance on how to apply the ‘termination of your notification obligation’ in two specific scenarios.
A. Termination because of a change of the MNE Group
When a Belgian entity changes MNE Group (e.g. following an acquisition, merger, or restructuring), the Belgian administration specifies that a two-step approach applies:
1. Firstly, the Belgian entity must submit a notification indicating the “Termination of your notification obligation,” as it is no longer part of the former MNE group.
2. The Belgian entity must then file a “first notification” for its new MNE group, provided that the new group is also subject to CbC reporting requirements.
A modification of a previous notification is not allowed in this scenario.
B. Termination because the MNE Group no longer exceeds the EUR 750 million threshold
If the consolidated revenue of the MNE group falls below the EUR 750 million threshold, all Belgian constituent entities (both the ultimate parent and/or subsidiaries) must submit a notification indicating the “Termination of your notification obligation, due to no longer being a member of the MNE group”, as the CbC notification requirement no longer applies. The phrase ‘no longer being a member of the MNE group’ should be understood as no longer being part of an MNE group subject to CbCR reporting obligations.
The Belgian administration has also clarified when the option “modification of a previous notification” should be used. This option is strictly limited to situations where the constituent entity remains within the same MNE group and continues to be subject to the reporting obligation but the information change e.g. address, name or identity of the reporting entity.
