• Country-by-country reporting notifications: relaxation of legal requirements

Country-by-country reporting notifications: relaxation of legal requirements

22 May 2019

In principle, each Belgian entity that forms part of a group, subject to filing a Country-by-Country (CBC) report has, on an annual basis and at the latest on the last date of the reporting period, an obligation to notify to the Belgian Tax Authorities which group entity is the ultimate parent entity that will submit the CBC report.

A new law of 2 may 2019 (Belgian Official Journal 15.05.2019), brings changes to this notification obligation form 275 CBC NOT. More precisely, based on the new law of 2 May 2019, the notification by Belgian group entities, forming part of a group that is subject to filing a CBC report notification form, will only be required if the information differs from the information that was provided with respect to the previous reporting period. The modified CBC notification requirements take affect for reporting periods ending as from 31 December 2019.

We obviously welcome this new law as this will reduce, to a certain extent, the administrative burden imposed on taxpayers impacted by the Belgian Transfer pricing documentation requirements with respect to CBC notifications.

We kindly invite you to verify each year whether there are any changes compared to the last 275 CBC NOT form to see if a 275 CBC NOT form needs to be filed and to avoid administrative fines in this respect.



If you have any questions or if you would like to get assistance from one of our experts, please do not hesitate to contact the BDO Transfer Pricing team: