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 750 million or more must also fulfil the Country-by-Country reporting notification requirements (275 CBC NOT and/or 275 CBC if acting as the ultimate parent entity). For more background, see also our earlier newsflash.
The Royal Decree of 16 June 2024 had implemented notable changes to these forms for financial years commencing on or after 1 January 2025 going, in certain respects, beyond OECD documentation standards, particularly concerning the forms 275 MF and 275 LF.
Under the 2024 decree, taxpayers were obliged to attach specific documents to the form 275LF if indicated as available, including:
- Methodologies or principles applied
- Agreements and/or benchmarking studies
- Framework agreements
- Model contracts relating to intercompany transfer pricing documentation
Following the adjustments by the 2025 decree, the requirement to submit these documents with the form 275LF has been repealed. Taxpayers now only need to confirm the availability of these documents within their records, as was the case before.
Nevertheless, the following documents must still be attached when filing the form 275 LF for financial years commencing on or after 1 January 2025:
- Cost contribution agreements
- Advance Pricing Agreements (APAs) and advance decisions (rulings)
- Intercompany reinsurance agreements
The updated requirements for the forms 275 MF and 275 CBC NOT remain unchanged.
