The Belgian taxpayers should be aware of the transfer pricing documentation requirements and the applicable deadlines to comply with the requirements. The taxpayers have an obligation to prepare and file the following transfer pricing forms if certain thresholds are met according to Belgian tax law:
Local file (275 LF)
The Local file form is to be filed at the same time as the corporate income tax return. The deadline for the corporate income tax returns for FY 2019 is extended from 24 September 2020 to 29 October 2020; so this additional period also applies to Local file (275 LF).
Master file (275 MF)
The Master file form must be filed no later than 12 months after the last day of the reporting fiscal year of the multinational entity (MNE) group (i.e. for FY 2019 generally being 31 December 2020).
Country-by-country (CbC) report (275 CBC)
The CbC report must be filed no later than 12 months after the last day of the reporting fiscal year of the multinational entity (MNE) group (i.e. for FY 2019 generally being 31 December 2020).
CbC reporting notification (275 CBC NOT)
For periods ending on 31 December 2019 or later, Belgian constituent entities of an MNE group are no longer required to file the notification annually if the information already filed in previous CbC reporting notifications remains the same. When there are changes to the details of the CbC reporting entity, the CbC reporting notification will still need to be filed in Belgium by the last day of the MNE group’s financial year (i.e. for FY 2020 generally being 31 December 2020).
