Belgium’s SPF Finance has updated guidance on BEPS13 reporting, introducing a new Local File form (275.LF) for FYs from 1 January 2025 and clarifying the use of “Termination of notification obligation” for CbC filings (275.CBC.NOT), including procedures for MNE group changes and threshold reductions, while extending the 2025 filing deadline to 28 February 2026.
Belgium’s Federal Public Service (SPF) Finance has released a BEPS13 News update detailing the new Local File form issued in December 2025 and providing guidance on using the “Termination of notification obligation” for CbC filings (275.CBC.NOT).
New Local File form
A new form model for the local file transfer pricing (275.LF) was published in the Belgian Official Gazette on 19 December 2025. It replaces the model originally established by the Royal Decree of 16 June 2024.
For financial years commencing on or after 1 January 2025, the obligation to attach documents relating to the section “Transfer price methodology and studies per business unit and per nature of the transaction (B10)” is abolished. For these documents, you only need to confirm their availability, as was the case previously.
However, if applicable, you still have to append the following documents relating to the section “Cost contribution agreements, advance pricing agreements, rulings and in-house (re)insurance policies (B12)” to the local file transfer pricing, in PDF format:
- the cost contribution agreements
- the advance pricing agreements (APAs)
- the rulings and in-house (re)insurance policies
Clarification regarding the use of “Termination of notification obligation”
SPF also clarified the correct procedure for completing the notification 275.CBC.NOT (Notification obligation concerning Country-by-Country Report) in two specific situations:
- Change of MNE Group
Where a Belgian constituent entity changes MNE group (e.g. through acquisition or restructuring), the option “modification of your previous notification” is not permitted. To clearly distinguish obligations between the former and the new group, you must mandatorily proceed in two steps:
- First, you must submit a notification of “termination of your notification obligation due to no longer being part of the MNE group” in order to record the exit from the former MNE group.
- Next, you must submit a “first notification” in order to record the entry into the new MNE group.
- MNE Group falling below the EUR 750 million threshold.
Where the consolidated gross revenue of an MNE group falls below the EUR 750 million threshold, the CbC reporting obligation ceases. To administratively close this obligation, the Belgian constituent entity (whether it is the Ultimate Parent Entity or a subsidiary) has to submit a notification selecting the option “termination of your notification obligation due to no longer being part of the MNE group”.
Note: In this specific context, “MNE group” should be administratively interpreted as a “qualifying MNE group” (i.e. a group meeting the threshold requirements).
You cannot use the option “modification of your previous notification”. 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 (e.g. in the event of a change of address, name or identity of the reporting entity).
Extension of the filing deadline
The deadline for the submission of the Country-by-Country notification (275.CBC.NOT) has been postponed to 28 February 2026 for financial years closing on 31 December 2025. The original deadline was 31 December 2025.
The FPS Finance is granting this extension in order to take into account the technical difficulties encountered during the transition to the new XML tool and to facilitate compliance with the reporting obligations.
This measure is taken in the context of the availability of:
- the new XSD schema
- the new XML BEPS13 XML creator tool.
