Belgium’s tax authorities have outlined updated BEPS 13 requirements for CbC notifications, master files, and local files, including new XML schemas, extended filing deadlines, enhanced documentation requirements, and stricter data-quality and compliance controls.
Belgium’s tax authorities hosted a webinar attended by over 200 participants to address technical implementation requirements for updated BEPS 13 reporting forms on 7 September 2026.
The session covered the country-by-country (CbC) notification (Form 275-CBC NOT), master file (Form 275-MF), and local file (Form 275-LF), including CbC reporting, filing deadlines, substantive changes, compliance obligations, and the tax authorities’ enforcement approach.
The key takeaways are:
Local file (Form 275-LF) and substantive changes
The XSD schema for the local file form was published on 2 September 2026 and confirmed as final. MyMinfin filing opened the same day with submissions receiving “received” status only. Form 275-LF filing was extended through 10 November 2026, though the corporate income tax return must still meet standard deadlines.
Key substantive changes require mandatory breakdown of cross-border transactions by business unit, country, and transfer pricing method. Cost contribution agreements, advance pricing agreements, rulings, and internal insurance or reinsurance arrangements referenced in section B12 must be attached as readable PDFs; subsequent years require only reference to previously submitted documents remaining in force.
Tax identification numbers (TINs) must be provided for Belgian entities’ competitors and foreign permanent establishments. Where TINs are unavailable, taxpayers may use alternative identifiers in order of preference: legal entity identifier, EU unique identifier, or local identification number with explanation. The value “N/A” is permitted only as a last resort with supporting documentation; blank fields and dummy values are not acceptable and may trigger penalties if systematic.
Filings under the old local file XSD schema are no longer accepted for corrective or new submissions.
Master file (Form 275-MF) and DEMPE documentation
The authorities confirmed no further substantive changes to the master file are expected beyond those introduced by the updated royal decree of June 2024. Technical developments, including migration of the XML tool and implementation of valid/invalid status and feedback letters, remain under implementation.
Master file documentation must include a group-wide value chain analysis describing key value drivers, transfer pricing policy, and alignment between actual remuneration and value creation, with focus on nonroutine activities supported by high-level financial figures at group or category level where reasonably available.
For DEMPE (development, enhancement, maintenance, protection, and exploitation) functions, reporting must cover significant intangibles at group level and demonstrate alignment between intellectual property profit allocation and respective entity DEMPE functions.
Hard-to-value intangibles require a description of the asset and HTVI treatment justification, identification of legal owner and development entities, and ex-ante pricing information only; groups without HTVI must include a corresponding statement.
For financing arrangements, documentation of major external financing must reconcile group-wide transfer pricing policy with actual financial results and ensure remuneration corresponds to functions and risks actually assumed.
CbC notification (Form 275-CBC NOT) and implementation timeline
The updated CbC notification form applies to multinational enterprises in scope for financial years beginning on or after 1 January 2025. Submissions must use new XML files based on the updated XSD schema, with filings under the old schema facing rejection. An extended filing period was granted through 28 February 2026 to allow necessary adaptation time.
MyMinfin filing access opened in December 2025, with valid or invalid status checks available from the end of May 2026. Automated feedback letters are expected from October 2026, and invalid filings should be corrected promptly.
The authorities outlined specific situations requiring notification updates: changes in group composition following restructuring or acquisition require termination of the previous notification and submission of a new first notification; liquidation requires a separate termination notification; and groups exceeding or falling below the reporting threshold must submit termination and new first notifications, with an exception applying to financial year 2025.
CbC reporting (Form 275-CBC) and Pillar Two interaction
The authorities emphasised the importance of CbC data quality, noting that a list of common reporting errors has been available on their website since May 2025. Future changes to Table 3 will require additional details on accounting standards, data sources, and exchange rates. Upcoming changes to CbC reporting Table 3, following OECD review, will require granular disclosure of accounting standards applied, data sources, and exchange rates applied.
Compliance and penalties
Belgium’s tax authorities apply a single, cumulative compliance framework across all four BEPS 13 forms, meaning penalties for one form in one year count as the first penalty for BEPS 13 purposes, with subsequent issues treated as repeat violations incurring higher penalties. Enforcement focus has shifted from late or nonfiling to systematic content quality review, with penalties imposed when audits reveal local file or master file deficiencies.
