Belgium updates Local File form under Royal Decree of 7 December 2025

On 7 December 2025, Belgium issued a Royal Decree replacing the Royal Decree of 16 June 2024, updating the model of the Local File form (275.LF) to be filed under article 321/5, §4 of the Belgian Income Tax Code (ITC 92). The Decree was published in the Belgian Official Gazette on 19 December 2025.

While the Royal Decree of 16 June 2024 had introduced significant changes to the Belgian transfer pricing documentation forms (for more detail please refer to our Tax Alert of 18 July 2024), the Royal Decree of 7 December 2025 now reverses certain changes to the 275.LF. The changes previously announced for the Master File Form (275.MF) and the country-by-country notification (275.CBC.NOT) remain valid. All changes are applicable for financial years starting on or after 1 January 2025.

Background

Belgium applies a three-tiered transfer pricing documentation framework consisting of:

• a Local File (275.LF);
• a Master File (275.MF); and
• a country-by-country reporting notification (275.CBC.NOT).

Belgian group entities and Belgian permanent establishments of foreign entities of multinational groups are required to file transfer pricing documentation when the statutory thresholds are exceeded. These obligations apply annually and form a core component of the Belgian transfer pricing compliance framework.

In July 2024, Belgium announced changes to the mandatory transfer pricing documentation and country-by-country reporting requirements. The recent Royal Decree of 7 December 2025 revisits some of these changes with respect to 275.LF.
 

Summary of the adaptations to the Belgian TP documentation requirements

The new Royal Decree of 7 December 2025 partially reverses the earlier announced adaptations to 275.LF, while leaving the adaptations to the 275.MF and 275.CBC.NOT unchanged as introduced by the Royal Decree of 16 June 2024. The main changes for the forms 275.LF, 275.MF and 275.CBC.NOT applicable for financial years starting on or after 1 January 2025 are described hereafter.

Local File form (275.LF):

The new model of 275.LF remains largely aligned with the previous model in terms of format and content. The key changes included in the explanatory notes to the new model 275.LF are outlined below:

• The existence or availability of a transfer pricing methodology or principle, transfer pricing and agreements should continue to be indicated in the form 275.LF. Whereas the Royal Decree of 16 June 2024 indicated that these documents must be submitted together with the form in a readable PDF-format, this was now removed in the latest Royal Decree. They continue to leave it up to the taxpayer to add these documents optionally in Section C1 of the form, if deemed useful for a better reading of the information provided in the 275.LF.
• With respect to cost contribution agreements, advanced pricing agreements, advance decisions (rulings) and intercompany re-insurance agreements, the latest Royal Decree continues to specify that it is expected that these will be appended by the taxpayer when submitting the 275.LF.

Prior announced changes include:

• A more detailed overview of intercompany transactions per business unit with cross-border transactions exceeding EUR 1 million is now required to be provided. There is a requirement for more detail per country of each counterparty, rather than providing data on an integrated basis. In addition, the explanatory notes to sections B3 to B6 now explicitly indicate that the applied transfer pricing method should be reported per transaction, per business unit and per counterparty country code.
• The Tax Identification Number (TIN) for the competitors of the Belgian entity and for the foreign permanent establishment of the Belgian entity should be listed.
   

Master File form (275.MF):

The Royal Decree of 7 December 2025 does not amend the 275.MF. Consequently, the enhanced expectations introduced by the Royal Decree of 16 June 2024 remain applicable.

These additional content-related expectations include:

• The inclusion of a more robust analytical framework for the group’s value chain and functional analysis, requires deeper insight into value creation and alignment with transfer pricing outcomes.
• More detailed information on the DEMPE functions with respect to intangibles is expected. This includes a detailed analytical framework for DEMPE functions, but also a list of transferred hard-to-value intangibles for example.
• Expanded transfer pricing policy disclosures for financing arrangements, going beyond the OECD Guidelines, including detailed information on financial guarantees, captive insurance and related structures.

These changes are further defined in the explanatory notes and go beyond what is required under the OECD Guidelines.
 

Country-by-country reporting notification (275.CBC.NOT)

The new Royal Decree does not amend the form 275.CBC.NOT anymore, which implies that the adaptations stipulated in the Royal Decree of June 2024 remain valid.

While the form has not changed substantially, taxpayers must now indicate whether the filing concerns:

• a first notification;
• a modification of a previous notification, or
• a termination of the notification obligation.

The main change compared to the past is that it is now also required to file 275.CBC.NOT in case of a termination of the notification obligation. The updated XSD scheme of the Belgian tax authorities was published on 1 December 2025. In light of these changes, an extension for the submission of the 275.CBC.NOT has been granted until 28 February 2026 for groups with a financial year ending on 31 December 2025.
 

Key takeaways and considerations

Multinational groups should reassess their Belgian transfer pricing documentation processes for financial years starting on or after 1 January 2025. Key takeaways include:

• Increased emphasis on structured data disclosures and consistency: The revised 275.LF places greater emphasis on structured disclosures within the form itself, requiring taxpayers to ensure strong alignment between reported information, underlying data and the overall transfer pricing framework. This increases the need for having a well-defined data governance framework with proper operational transfer pricing processes. It also demonstrates that the Belgian tax administration has enhanced capabilities and access to data to start more targeted audits.
  
  
• Have the required TP documentation available: Having transfer pricing documentation and agreements remains important, but they do not need to be submitted with the form 275.LF. With respect to cost contribution agreements, advanced pricing agreements, advance decisions (rulings) and intercompany re-insurance agreements, the latest Royal Decree continues to expect that these will be appended to the 275. LF by the taxpayer.
  
  
• Belgian Master File expectations exceed OECD standards: The enhanced Master File requirements introduced in the former Royalty Decree remain applicable. These expectations go beyond the OECD Guidelines and taxpayers should evaluate how to address these expectations of the Belgian tax administration.