In brief
Local File Form (275.LF) filing deadline extended to 10 November 2026. The Belgian tax authorities have extended the filing deadline for the 2025 Local File Form (275.LF) to 10 November 2026. The extension applies to Local File Forms (275.LF) which originally had to be filed earlier, i.e., on 30 September 2026 for taxpayers with a financial year per calendar year. The extension is granted in the context of the late finalisation of the electronic (XSD) schema for the revised Local File Form (275.LF) and the pending update of the authorities’ XML file creation tool.
The filing deadlines for the corporate income tax and non-resident corporate income tax returns, which typically coincide with the filing deadlines for the Local File, remain unchanged, i.e., 30 September 2026 for financial years closed on 31 December 2025.
New requirements regarding TP Documentation. Belgium has significantly reshaped its transfer pricing documentation framework through two waves of reform, which now become for the first time applicable for the reporting on financial year 2025.
On 15 July 2024, three Royal Decrees dated 16 June 2024 were published in the Belgian Official Gazette, substantially revising Belgium’s Transfer Pricing (TP) documentation requirements (hereafter "2024 Royal Decrees"). On 19 December 2025, a new Royal Decree dated 7 December 2025 was published in the Belgian Official Gazette, partially revising the changes introduced by the Royal Decree of 16 June 2024 and updating the Local File Form (275.LF) applicable for financial years starting on or after 1 January 2025 (hereafter "2025 Royal Decree").
Background
Belgium applies a three‑tier transfer pricing documentation framework consisting of a Local File Form (275.LF), a Master File Form (275.MF) and a Country‑by‑Country (CbC) Notification (275.CBC.NOT)/Country‑by‑Country (CbC) Report (275.CBC).
Belgian entities and Belgian permanent establishments of multinational groups exceeding statutory thresholds must file the Local File Form (275.LF) and Master File Form (275.MF) annually.
The Royal Decree of 16 June 2024 significantly expanded the detail and scope of reporting, particularly within the Local File Form (275.LF) and Master File Form (275.MF). The Royal Decree of 7 December 2025 adjusts this framework by easing certain burdens while maintaining the overall objective of enhanced transparency.
Local File (275.LF)
The Local File Form (275.LF) is where the most visible changes have occurred. The additional requirements introduced by the 2024 and 2025 Royal Decrees in respect of the Local File Form (275.LF) include, amongst other, the following:
- Intercompany transactions must be disclosed per business unit and per country when cross-border transactions exceed EUR 1 million.
- Taxpayers must provide Tax Identification Numbers (TINs) for key competitors and any foreign permanent establishments, as well as country codes and TINs for relevant counterparties such as those involved in cost contribution agreements, APAs, rulings and in-house (re)insurance policies.
- Cost contribution agreements, advanced pricing agreements, advance decisions (rulings) and intercompany re‑insurance agreements are expected to be attached to the Local File Form.
The 2025 Royal Decree introduced one significant relief: taxpayers are no longer required to append TP methodologies, TP principles, framework agreements, model contracts and TP studies when submitting the Local File Form (275.LF). They must, however, still indicate in the Local File Form (275.LF) whether these documents are available, but attaching them is optional.
The new Local File Form (275.LF), applicable to financial years starting on or after 1 January 2025, continues thus to require detailed country-by-country transactional information and certain important agreements.
Filing of the revised Local File Form (275.LF). The revised Local File Form (275.LF) must be filed electronically via the Belgian tax administration’s online platform, MyMinfin, and in XML format. The final XSD schema for the new form was only published early September 2026 and the authorities’ updated XML file creation tool is expected by the end of September 2026. In light hereof, the filing deadline for Local File Forms (275.LF) has been extended to 10 November 2026. Taxpayers that generate their own XML files on the basis of the final XSD schema may file ahead of the release of the updated tool. Given the more granular data required (transactions per business unit and per country, TINs and mandatory attachments), we recommend, however, that taxpayers use the additional time to reconcile the data in the Local File Form (275.LF) with their underlying transfer pricing documentation. Indeed, Belgian tax authorities rely on advanced data-mining tools to launch transfer pricing audits so that consistency between statutory figures and documentation is essential.
Master File (275.MF)
The Master File Form (275.MF) reforms introduced by the 2024 Royal Decrees remain fully applicable, as the 2025 Royal Decree did not amend this form:
- The updated Master File Form (275.MF) now calls for a more extensive explanation of how value is generated across the group. It requires a four‑part analysis that traces the group’s value chain and functions, and places particular emphasis on how profits are allocated internally. This includes demonstrating whether the profit allocation is consistent with the transfer pricing outcomes, ensuring that the reported results reflect the actual economic contributions of each entity.
- A second element of the revised requirements concerns intangible assets. Taxpayers must provide a detailed description of how responsibilities relating to the Development, Enhancement, Maintenance, Protection and Exploitation of intangibles are divided within the group. This six‑dimension framework ensures that the roles and decision‑making functions behind intangible assets are clearly documented and transparently assigned.
- The Master File Form (275.MF) must also address any hard‑to‑value intangibles used or transferred during the reporting period. This includes describing their nature, the circumstances of their use or transfer, and any factors that may affect their valuation or reliability of pricing.
- Finally, the new rules introduce minimum disclosure standards regarding the group’s approach to intragroup financing. Taxpayers must set out the general transfer pricing policy applied to financial transactions, providing insight into how funding arrangements are structured, priced and aligned with the broader transfer pricing framework.
As for the Local File Form, these new requirements apply for Master File Forms with respect to financial years starting on or after 1 January 2025. The Master File Form must, however, only be filed by the end of the financial year following the reporting period.
Groups have the option to include the additional required information for Belgian filing purposes in their Master File or in attachment thereto (with this attachment then only being used for filing in Belgium).
Country-by-Country Notification (275.CBC.NOT)
The 2024 Royal Decree also updated the CbC notification Form which requires taxpayers to identify the group company filing the CbC Report. The Belgian taxpayer will now also need to indicate whether the filing is a first submission or a modification or termination of an earlier submission.
A new XSD schema also applies for financial years beginning on or after 1 January 2025.
Conclusion
Belgium’s reforms through the 2024 and 2025 Royal Decrees jointly establish a more demanding transfer pricing documentation regime in Belgium. The 2025 Royal Decree offers limited relief by eliminating the obligation to upload certain supporting documents but largely preserves Belgium’s objective of enhanced transparency and more robust informational filings.
For taxpayers following a normal calendar year (i.e., financial year ending 31 December 2025), the revised Local File Form (275.LF) for financial year 2025 must now be filed by 10 November 2026 (extended from 30 September 2026).
We continue to help our clients navigating their TP documentation obligations and are happy to address any further queries you may have for which you can reach out to your Baker McKenzie contact persons.