Transfer pricing studies not required to be submitted with local file form

A royal decree of 7 December 2025, published in the Belgian official gazette on 19 December 2025 (Dutch | French), has reversed a significant change to the Belgian local file form (Form 275 LF) requirements intended to apply for financial years starting on or after 1 January 2025. As a result, taxpayers will not now be required to append their transfer pricing studies, in PDF format, to Form 275 LF.

Other significant changes to the Belgian transfer pricing documentation forms introduced by the prior royal decree of 16 June 2024 remain applicable for financial years starting on or after 1 January 2025, for which the forms are to be submitted for the first time during calendar year 2026 (see our Tax Alert of 17 December 2024).

Following publication of the royal decree of 7 December 2025, the new requirement to append methodologies or principles, framework agreements or model contracts, and transfer pricing studies in a readable PDF format to Form 275 LF has been revoked. However, it remains mandatory to indicate the existence of such documentation on the form, and taxpayers may still choose to append the documents in section C1 of the form if they believe it would be useful for a better understanding of the information provided.

It is important to note, however, that the explanatory notes to the new form still specify an expectation that certain agreements will be appended by the taxpayer upon submission of the form. These include:

• Cost contribution agreements (CCAs);

• Advance pricing agreements (APAs);

• Advance decisions (rulings); and

• Intercompany reinsurance agreements. 

Other transfer pricing documentation changes for financial years starting on or after 1 January 2025

The new royal decree focuses only on the submission of transfer pricing studies with Form 275 LF. The other significant amendments introduced in June 2024 for financial years starting on or after 1 January 2025 are unaffected, including:

Form 275 LF (local file form)

• Transaction reporting: All transactions must be reported per business unit and per country code, which will significantly increase transparency and enable the Belgian tax authorities to track more accurately intercompany transactions involving other jurisdictions.

• Inclusion of tax identification number: The tax identification number (or equivalent) of the most important competitors (section A6) and the company’s permanent establishments (section B11) should be included.

• Inclusion of country code: The country code for certain relevant parties to CCAs, APAs, rulings, and in-house (re)insurance policies should be included.

Form 275 MF (master file form)

• While there are no changes to the form itself, the explanatory notes have been expanded, requiring significant additional information and analysis. Some of the new requirements in the explanatory notes go beyond what is typically included in an OECD compliant master file report. For non-Belgian headquartered groups, a localised version may be required to meet the Belgian requirements.

• The main additional requirements in accordance with the explanatory notes are summarised in our Tax Alert of 17 December 2024.

Form 275 CBC NOT (country-by-country (CbC) reporting notification)

• It is possible to indicate whether the notification is an initial notification, a modification of a previous notification, or a termination of the reporting obligations as a result of no longer being part of the multinational enterprise group. This addition addresses previous shortcomings, providing clear distinctions between different types of notifications and streamlining the notification process.

• The deadline for submission of Form 275 CBC NOT for fiscal years closing on 31 December 2025 has been postponed from 31 December 2025 to 28 February 2026, owing to technical difficulties encountered during the transition to the new XML tool.

Key takeaways

• Importance of having TP documentation available: The removal of the requirement to append transfer pricing studies to the local file form does not remove the requirement to have TP documentation available. Documentation still needs to be provided to the Belgian tax authorities upon request, and therefore it remains crucial that documentation is prepared and reviewed annually, to ensure full compliance with Belgian transfer pricing regulations.

• Master file: With the expansion of the explanatory notes, it is important for taxpayers to review their group master file and determine to what extent additions are needed for Belgian transfer pricing purposes, either directly as part of the group master file or by means of an appendix to the group master file.

It remains clear that transfer pricing is high on the agenda of tax authorities globally, including in Belgium, and that taxpayers should pay significant attention to the requirements to ensure a clear alignment between documentation, form obligations, and underlying data.

Deloitte can support taxpayers at every stage, delivering comprehensive solutions to address compliance needs and enhance overall tax efficiency.