Adjustments to the Belgian transfer pricing forms as from financial year 2025
Adjustments to the Belgian transfer pricing forms as from financial year 2025
The Royal Decree dated 16 June 2024 and published on 15 July revises some of the Belgian transfer pricing documentation requirements.
More specifically, the intercompany transactions to be included in the part B of the Belgian Local File Form (275LF) will need to be segregated per jurisdiction providing the more detailed overview to the tax authorities. Until now, for each intercompany transaction the data are aggregated in one row, irrespective of the jurisdiction of the counterparty.
This new step enables greater alignment with the OECD Transfer Pricing Guidelines and the Council Directive (EU) 2016/881. In practice, such an increased transparency aims at strengthening the accuracy of the data mining performed by the tax administration, the efficiency of the risk assessment by focussing on specific transactions and the screening of inconsistencies by comparing multiple sources of information.
The revision of the Local File Form (275-LF) will be effective as from financial years starting 1 January 2025.
Is your Belgian company or permanent establishment involved in cross-border intercompany transactions, please do not hesitate to contact Transfer pricing - BDO for additional information regarding the Belgian transfer pricing documentation requirements.
This new step enables greater alignment with the OECD Transfer Pricing Guidelines and the Council Directive (EU) 2016/881. In practice, such an increased transparency aims at strengthening the accuracy of the data mining performed by the tax administration, the efficiency of the risk assessment by focussing on specific transactions and the screening of inconsistencies by comparing multiple sources of information.
The revision of the Local File Form (275-LF) will be effective as from financial years starting 1 January 2025.
Is your Belgian company or permanent establishment involved in cross-border intercompany transactions, please do not hesitate to contact Transfer pricing - BDO for additional information regarding the Belgian transfer pricing documentation requirements.