On 4 September 2026, the Belgian tax authorities announced that the filing deadline for Form 275 LF (Local File Form) has been extended up to and including 10 November 2026.

Ongoing conflicts and geopolitical tensions in Ukraine and the Middle East have contributed to volatility in oil and gas prices and to higher inflation expectations. Against this backdrop, financial markets have increasingly priced in a higher interest-rate environment. In June 2026, the ECB raised its three key interest rates by 25 basis points. While the ECB has emphasized that future monetary policy decisions will remain data-dependent and will be taken on a meeting-by-meeting basis, financial markets are currently anticipating a further increase of 25 basis points in the ECB rates in September.

On 15 June 2026, the Belgian Ruling Commission published its 2025 annual report. The report provides insight into the functioning of the ruling practice, recent operational developments and key trends in areas such as transfer pricing and the innovation income deduction.

Overall, the report, available in Dutch and French, confirms a more demanding ruling environment, with decisions increasingly driven by economic substance, factual consistency and robust supporting documentation.

The interaction between value-added tax (VAT) and transfer pricing (TP) remains a key area of tension in EU tax law. In the Stellantis Portugal Case (C-603/24), the CJEU clarifies that transfer pricing adjustments aimed at achieving a target margin are not consideration for services and, depending on the circumstances, may be regarded as adjustments to the price of the underlying transaction.  This case once again illustrates that the VAT treatment of transfer pricing adjustments always depends on the underlying facts and must therefore be assessed on a case-by-case basis.

In a globalized economy in which multinational enterprises organize their activities through increasingly complex and cross-border value chains, transfer pricing remains a structural source of tax uncertainty. This is particularly true for so-called baseline marketing and distribution activities, where such limited functions still often give rise in practice to complex discussions, divergent tax interpretations and lengthy disputes between taxpayers and tax administrations.

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.

On 10 September 2025, the Belgian Ruling Commission published its annual report for 2024. The report, available in Dutch and French, provides insights into key trends, operational developments, and notable decisions in the field of tax rulings.

The Arcomet Case

The VAT treatment of transfer pricing (“TP”)-adjustments has been a complex and often ambiguous area within EU tax law. The outcome of the Arcomet case set an important precedent for the VAT treatment of TP adjustments across the EU. This case follows the earlier opinion of the Advocate General, which already hinted at a VAT inclusive interpretation. Now, the CJEU has confirmed that non-transactional TP adjustments can indeed be subject to VAT, provided certain criteria are met.

The relationship between transfer pricing (TP) adjustments and value-added tax (VAT) is often complicated. Recently, the Arcomet case, which was reviewed by the Advocate General of the Court of Justice of the European Union (CJEU), has highlighted this issue. This case offers a unique chance to clarify how VAT should be applied to intragroup transactions when TP adjustments are involved.

On 19 February 2025, the OECD released the report on Amount B of Pillar One, providing a Simplified and Streamlined (S&S) approach to determine an arm’s length remuneration for baseline marketing and distribution activities. This standardized methodology eliminates the need for a benchmark and establishes a fixed return on sales ranging from 1.5% to 5.5%.