Tax administration clarifies updated BEPS 13 transfer pricing forms and CbC reporting

On 7 September 2026, the Belgian tax authorities held a webinar addressing the technical and practical implementation of the updated BEPS 13 forms, specifically the country-by-country (CbC) notification (Form 275-CBC NOT), master file (Form 275-MF), and local file (Form 275-LF). The tax authorities also discussed certain details related to CbC reporting. Attended by more than 200 participants, the session focused on the most frequently raised questions, particularly regarding the updated requirements for the master file and local file.

This alert summarises the key takeaways for taxpayers, with an emphasis on upcoming deadlines, new technical filing requirements, and the tax authorities’ compliance approach.

Filing deadlines and technical status

CbC notification (Form 275-CBC NOT)

The updated CbC notification form applies to in-scope multinational enterprises for financial years starting on or after 1 January 2025. Key points include:

• Schema requirement: Submissions must use the new XML files based on the updated XSD schema; filings under the old schema will be rejected.

• Extended filing period: An extended filing period was granted until the end of February 2026 to allow sufficient time for adaptation.

• MyMinfin access: Filing through MyMinfin has been possible since December 2025. Since the end of May 2026, filers have been able to check whether their submitted files have been assigned a valid or invalid status.

• Backend validation: Automated feedback letters (confirming valid filings or listing detected errors) are expected to be rolled out during October 2026. Corrections to invalid filings should be made as soon as possible, ideally well before the applicable deadline.

Special situations requiring notification updates:

• Change of group: Following a restructuring or acquisition, a termination notification for the previous group must be submitted, followed by a new first notification for the new group.

• Liquidation: A separate termination notification is required; this cannot be inferred from the Crossroads Bank for Enterprises publication.

• Threshold changes: A group exceeding the reporting threshold (up or down) requires a termination notification followed by a new first notification, with an exception applicable to the financial year 2025.

Looking ahead, under the proposed EU directive on administrative cooperation recast, a single EU-wide notification (covering both the CbC report and the top-up tax information return) with a common template and filing deadline is being considered for the future.

Local file (Form 275-LF)

The XSD schema published on the tax authorities’ BEPS 13 website on 2 September 2026 for the local file form has now been confirmed as final. Deloitte Belgium can assist with the conversion to XML via our own XML conversion tool, as well as with the filing of the XML via MyMinfin, as filing through MyMinfin opened on 2 September 2026, with the following key details:

• Extended deadline: The filing deadline for the local file has been extended up to and including 10 November 2026. This extension applies strictly to the local file (Form 275-LF); the corporate income tax return itself must still be filed within the normal deadline. The applicable box in the corporate tax return that refers to the local file form obligation should be checked.

• Status check: At this stage, local file submissions only receive a “received” status. In the future, taxpayers will be able to verify the valid/invalid status, whereas feedback letters will become available once all technical functionalities have been fully rolled out.

Key substantive changes to the local file form:

• Cross-border transaction breakdown: Cross-border transactions must now be broken down per business unit, by country, and by transfer pricing method.

• Supporting documentation: Cost contribution agreements, advance pricing agreements, rulings, and internal insurance/reinsurance arrangements referenced in section B12 must be attached as readable PDFs. In subsequent years, a reference to the previously submitted document will suffice, provided it remains in force.

• Tax identification numbers (TINs): TINs must be provided for Belgian entities’ competitors and for foreign permanent establishments where applicable. In section B12, both the TIN and the relevant country code must now be provided.

• Alternative identifiers: Where a TIN is not available, taxpayers may use an alternative identifier in the following order of preference: legal entity identifier, EU unique identifier, or another local identification number (with explanation of its nature and source in an annex). The value “N/A” may only be used as a last resort, supported by documentation explaining the absence of a TIN. Blank fields, dummy values, or omissions are not acceptable and, if systematic, may lead to penalties.

Filings under the old local file XSD schema can no longer be used for corrective filings (related to previous financial years) or new submissions; only the current schema will be accepted going forward.

Master file (Form 275-MF)

The tax authorities have confirmed that no further substantive changes to the master file are currently expected beyond those introduced by the updated royal decree of June 2024. However, related technical developments (such as migration of the XML tool, valid/invalid status, and feedback letters) are still to be implemented.

The tax authorities emphasised that the master file is a group-wide document rather than a Belgian-specific report, and the new disclosures should therefore be prepared on that basis. They may be included in a separate annex to the master file.

The tax authorities have clarified expectations on the new requirements as follows:

Value chain analysis

Taxpayers are now expected to provide a high-level, group-wide (rather than entity-level) description of:

• The group’s key value drivers and transfer pricing policy; and
• Whether actual remuneration is consistent with value creation.

The tax authorities have indicated that focus should be on nonroutine activities, potentially supported with high-level financial figures at group/category level (to the extent reasonably available).

Development, enhancement, maintenance, protection, and exploitation (DEMPE) functions

Reporting should cover:

• Significant intangibles to be reported at group level (rather than every asset), including the outsourcing of DEMPE functions (if any); and

• Demonstration that intellectual property profit allocation is aligned with the relevant DEMPE functions of the respective entities, as opposed to legal ownership alone.

Hard-to-value intangibles (HTVI)

The master file should include:

• A description of the intangible and reasons for HTVI treatment;

• The legal owner and entities involved in its development; and

• Only ex-ante pricing information.

If there are no HTVI, a corresponding statement is to be included in the master file form.

Financing arrangements

Taxpayers will have to document their most important external financing arrangements (e.g., bank loans or bonds). For each category of intercompany financing transactions (cash pooling, intercompany loans, trade receivables/payables, guarantees, treasury, and captive insurance activities), the following is expected to be documented:

• The group-wide transfer pricing policy (including applied transfer pricing method, benchmarking methodology, and implementation) must be described and reconciled against actual financial results; and

• Remuneration (e.g., of a cash pool leader or centralised treasury entity) must correspond to the functions and risks actually assumed, rather than being retained in full by the entity holding the funds.

CbC reporting (Form 275-CBC) and Pillar Two interaction

Data quality and upcoming changes

The tax authorities have reiterated the importance of data quality in CbC reporting. Reference was made to the list of common errors available on the tax authorities’ website since May 2025. Upcoming changes to table 3, following the OECD CbC reporting review, will require more granular disclosure of:

• Accounting standards applied;

• Data sources used; and

• Exchange rates applied.

Surrogate submitter rules

On the use of a surrogate submitter in Belgium, the tax authorities have confirmed they will apply a strict reading of the law. This is only accepted where:

• The ultimate parent’s jurisdiction has no CbC filing obligation;

• The ultimate parent’s jurisdiction has not concluded an applicable international exchange-of-information agreement; or

• The ultimate parent’s jurisdiction is subject to a systemic failure.

Consolidation adjustments

Regarding consolidation adjustments in the CbC report (which is a Belgian administrative position in the absence of OECD guidance), the following guidance was provided:

• Consistency of the data source used from year to year is key; and

• Where consolidation differences arise, the suggested approach is to exclude them from tables 1 and 2 and instead disclose them, with supporting amounts, in table 3 at group level.

Pillar Two safe harbour

Questions specific to Pillar Two should be directed to the dedicated Pillar Two mailbox, as this remains outside the scope of the BEPS 13 team.

Compliance and penalties

The tax authorities have confirmed that it applies a single, cumulative compliance framework across all four BEPS 13 forms. This means:

• A penalty incurred on one form (e.g., the local file form) in one year will be treated as a first penalty for BEPS 13 purposes; and

• Any subsequent issue in a later year, even related to a different form, will be treated as a repeat (and therefore higher) penalty.

Shift in enforcement focus

While penalties have historically focused on late filing or nonfiling, the tax authorities are now also applying a systematic review of content quality. Penalties may be imposed when, during an audit, the local file or master file is deemed to be lacking the necessary quality.

The tax authorities have indicated that they assume good faith and estimate that the majority of taxpayers are compliant.

Key takeaways

The overarching message was one of consistency. The CbC report, CbC notification, master file, and local file should tell “one consistent story” at group level, with figures, functional analysis, and transfer pricing outcomes being aligned across the group’s transfer pricing documentation.

Taxpayers are encouraged to use the currently applicable XSD schema for all filings, to file as early as possible to benefit from status feedback once available, and to begin preparing the required local file form as soon as possible, notwithstanding the extended deadline of 10 November 2026.