• Approaching deadline for filing transfer pricing formalities and documentation

Approaching deadline for filing transfer pricing formalities and documentation

01 March 2018

From the assessment year 2017, certain MNEs have to comply with transfer pricing documentation requirements. The Begian tax authorities announced at the end of last year that for the first year the deadline for filing of forms 275 MF and 275 CBC NOT was postponed until 31 March 2018.

 

 

Master File form

A Maste File form 275 MF for assessment year 2017 has to be submitted with the Belgian tax authorities before 31 March 2018 by each Belgian company or permanent establishment (of an MNE) that exceeds one or more of the following thresholds:

  • Combined operating and financial income of EUR 50 million
  • A total balance sheet of EUR 1 billion
  • Annual average number of 100 FTE’s

The abovementioned thresholds should be assessed on a stand-alone basis (i.e. in the hands of the Belgian entity) based on the financial statements of the preceding financial year. Please note that completing Form 275 MF takes time in case no Masterfile is available.

 

Country-by-Country notification

A Country-by-country notification form 275 CBC NOT for assessment year 2018 has to be submitted with the Belgian tax authorities before 31 March 2018 by each Belgian company or permanent establishment (of an MNE) that is part of a group with a consolidated gross turnover of at least EUR 750 million (to be assessed based on the consolidated financial statements of the group of the preceding financial year).

 

Format

Please note that these documents should be filed electronically in a valid XML format through the MYMINFINPRO platform. It is no longer allowed to file by e-mail using [email protected]). We can provide you with the Guidelines published by the Ministry of Finance and/or assist in filing these Forms.

 

Penalties

Failing to comply with the abovementioned transfer pricing obligations can lead to administrative penalties between EUR 1,250 and 25,000.

 

Contact

Should you have any questions regarding this topic or require assistance, please feel free to contact the BDO Transfer Pricing Team:

 

 

 

 

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