Starting from financial years beginning on or after 1 January 2025, Belgian Transfer Pricing documentation requirements have undergone important updates following two Royal Decrees: the Decree of 16 June 2024, which introduced major changes (see our previous article), and the Decree of 7 December 2025, which partially revised those measures for the Local File Form (275.LF). Below is an overview of the final changes affecting the three Belgian transfer pricing forms.

Local File Form (275.LF)

The form and the content of the new Local File Form 275.LF remains largely similar to the form as announced in the 2024 Royal Decree. The following explanatory notes to this new form 275.LF have been provided in the recent Royal Decree:

• Box B10: Taxpayers must still tick the box if a transfer pricing methodology, framework agreement, model contract or transfer pricing study exists. Under the June 2024 Decree, ticking the box required attaching these documents in PDF format. This obligation has now been removed. It remains optional for taxpayers to append these documents in Section C1.
• Supporting agreements: For cost contribution agreements, advanced pricing agreements, rulings and in-house (re) insurance policies, the latest Royal Decree confirms that these documents are expected to be provided by the taxpayer when submitting Form 275.LF.

Changes already in place based on the Royal Decree of 2024:

• Part B: For taxpayers with cross border intercompany transactions per business unit exceeding EUR 1 million, transaction volumes must now be reported per country, rather than on an integrated basis for all countries combined. This requirement applies to boxes B3, B4, B5 and B6. In addition, the explanatory notes to these sections explicitly state that the applied transfer pricing method must be reported for each transaction, per business unit and per country.
• Additional Information: The Tax Identification Number (TIN) must be provided for entities listed in Box A6 (main competitors) and Box B11 (permanent establishments).

Master File From (275.MF) and CBC Notification Form (275.CBC.NOT)

The Royal Decree of 7 December 2025 does not introduce any changes to Form 275.MF and Form 275.CBC.NOT. Consequently, the enhanced expectations set out in the Royal Decree of 16 June 2024 remain fully applicable. Below, we provide a recap of the key modifications to these forms and highlight the main points of attention for taxpayers.

Master File (Form 275.MF)

• Value chain and functional analysis: Taxpayers must provide a more comprehensive description of the group’s value chain and functional analysis, structured in four steps:
  • Identify the ‘value drivers’
  • Make a functional analysis of key functions, risks and assets
  • Allocate profit to entities according to value creation by primary function and
  • Compare with transfer pricing results

• Intangible assets and DEMPE functions: A detailed DEMPE analysis is required, including identification of legal owners and entities performing DEMPE functions. Taxpayers must also provide a list of intangible assets transferred or used that are hard to value.

 

• Financing Arrangements: Expanded disclosures are expected for financial transactions, including principles for establishing commercial or financial relationships, determination of market conditions for treasury activities (such as intercompany loans, cash pooling and hedging), treatment of financial guarantees, and analysis of in-house (re)insurance arrangements.

 

Country-by-Country Reporting Notification (275.CBC.NOT)

Taxpayers must now clearly indicate whether the filing concerns: a first notification, a modification of a previous notification, or a termination of the notification obligation.

It is now also required to file the new notification form in case of termination of the notification obligation. In addition, the updated XSD scheme for electronic submission was published by the Belgian tax authorities on 1 December 2025. To accommodate these changes, an extension for filing Form 275.CBC.NOT has been granted until 28 February 2026 for groups with a financial year ending on 31 December 2025.

Key takeaways

Belgium is clearly moving toward a more data-driven and transparent approach to transfer pricing compliance. The recent updates emphasize structured reporting, consistency between documentation and underlying data, and expanded disclosures that go beyond OECD standards.

Multinational groups should review their Belgian transfer pricing documentation for financial years starting on or after 1 January 2025. Taxpayers are advised to proactively assess their processes, align internal systems and prepare for a higher level of detail and transparency in reporting, given the increased scrutiny.  

For any further questions or assistance, please do not hesitate to contact your trusted Tiberghien advisor.

Authors: Tine Slaedts & Stefanie Van der Straeten