Authors: Joke Gysens and Sarah Keulemans

Since 2016, Belgium has required a three-part transfer pricing documentation system consisting of a Master File, a Local File and a Country-by-Country Report (CbCR).

For financial years starting on or after 1 January 2025, stricter documentation requirements apply. In addition, the deadlines for submitting transfer pricing documentation for financial year 2025 are approaching.

We outline the key points below, so that your company can prepare in good time.

When are a Local File and Master File required?

A Local File and Master File must be submitted when your Belgian entity is part of a multinational group and, during the financial year preceding the reporting year, exceeds at least one of the following thresholds:

• turnover of €50 million;
• an average workforce of 100 FTEs;
• a balance sheet total of €1 billion.

The assessment is based on the standalone financial statements of the Belgian company for the most recently closed financial year.

Local File deadline for financial year 2025

In Belgium, the Local File must in principle be submitted within the same timeframe as the corporate income tax return or the non-resident corporate income tax return.

For entities with a calendar financial year, the filing deadline for financial year 2025 was originally set for 30 September 2026, together with the corporate income tax return.

However, due to changes to the form resulting from the more extensive substantive requirements, a general extension was granted. The new deadline for submitting the Local File is 10 November 2026.

Please note that the filing deadline for the corporate income tax return remains unchanged. Recently, tax authorities have also extended the submission deadline for the CIT returns to 15 October 2026.

Master File deadline for financial year 2025

The Master File must be submitted no later than 12 months after the last day of the group’s reporting period.

For groups whose financial year ends on 31 December, this means that the deadline for financial year 2025 is 31 December 2026.

Stricter transfer pricing documentation requires timely preparation

More extensive documentation requirements have applied since financial year 2025. In our earlier article on the new transfer pricing documentation requirements in Belgium, we discussed these changes in detail.

The substantive changes represent a significant tightening of the documentation requirements. For the Master File, Belgian requirements also go beyond what is required internationally. As a result, companies in Belgium may need to provide more information than companies in other countries.

These stricter requirements call for a thorough analysis of the group-level transfer pricing policy and, where necessary, additional information in the existing Master File documentation.

It is therefore important for your company to have a robust and fully developed transfer pricing policy that is in line with the OECD Guidelines. This should be supported by a high-quality and comprehensive Local File and Master File.

The stricter transfer pricing documentation requirements in Belgium are not a temporary trend, but form part of a broader international development aimed at combating tax evasion.

Transfer pricing is receiving increasing attention during tax audits

Tax authorities worldwide are paying increasing attention to transfer pricing. This is reflected in legislative, administrative and judicial developments.

In Belgium, the transfer pricing documentation requirements have been reformed and enforcement capacity has been strengthened, including through the expansion of the specialised transfer pricing unit. At the same time, the tax administration is applying its penalty policy more strictly. This underlines the importance of accurate documentation and a sound substantiation of intra-group transactions.

Transfer pricing also remains an important international issue. This is illustrated, among other things, by the recent Stellantis Portugal judgment (C-603/24), in which the Court of Justice addressed the relationship between transfer pricing adjustments and VAT.

These developments confirm that transfer pricing remains an important consideration for companies and their tax compliance obligations.

Companies that underestimate the requirements or treat transfer pricing documentation as merely a formal exercise expose themselves to significant tax and financial risks. With the deadlines approaching, it is therefore advisable to start preparing your transfer pricing documentation for financial year 2025 as soon as possible.

Country-by-Country Reporting (CbCR), public CbCR and Pillar Two

In addition to the Local File and Master File, there are additional obligations for groups with consolidated business revenues of at least €750 million per year.

Multinational groups with Belgian entities that exceed this threshold are subject to both CbC and Pillar Two requirements. The Pillar Two requirements may also apply to purely Belgian multinational groups.

These are the key deadlines:

• Country-by-Country Report (CbCR): no later than 12 months after the last day of the group’s reporting period.
• CbCR notification: no later than the last day of the group’s reporting period.
• Public CbCR: no later than 12 months after the last day of the group’s reporting period.
• Pillar Two domestic top-up tax return: no later than 11 months after the last day of the group’s reporting period.

For the Pillar Two domestic top-up tax return, the reporting period for financial year 2024 remains open until 31 October 2026. The deadline for financial year 2025 is also approaching and falls on 30 November 2026.