Global Tax Alert (News from Transfer Pricing) | 29 November 2017

Belgium postpones year-end transfer pricing filing deadline until 31 March 2018

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On 28 November 2017, the Belgian tax authorities announced that they would extend the filing deadline to 31 March 2018 for the three transfer pricing reporting obligations – the master file, the Country-by-Country (CbC) report and the CbC report notification – which were initially due by the Belgian entities of a multinational enterprise (MNE) by 31 December 2017.

In 2016, Belgium introduced mandatory transfer pricing documentation requirements in accordance with Action 13 of the Organisation for Economic Co-operation (OECD) Base Erosion and Profit Shifting (BEPS) project, i.e., master file, local file, and CbC reporting (CbCR). These new requirements apply as of financial years starting on or after 1 January 2016. Practically, this means that for Belgian affiliates or permanent establishments of an MNE group with a financial year ended on 31 December 2016, the first deadline for filing a 2016 CbC report (275.CBC) and/or 2016 master file (275.MF) will now be 31 March 2018 (provided that the applicable thresholds are met). In addition, for affiliates or permanent establishments of an MNE group with a financial year ending on 31 December 2017, the deadline to file the 2017 CbCR notification form (275.CBCNOT) is no later than 31 March 2018. These documents need to be filed in an XML-format on the platform of the Belgian tax authorities, MyMinfinPro.

As the requirements to file the above forms vary, each Belgian entity should review its own circumstances to determine which of the above forms would need to be filed by 31 March 2018.

The local file (275.LF) deadlines remain unchanged and should still be filed at the same time the Belgian tax return is filed. For Belgian entities with financial years started on or after 1 January 2017, all local files should also be filed in an XML-format on the MyMinfinPro platform of the Belgian tax authorities. Belgian entities with a financial year started on or after 1 of January 2016 and which still have to file their tax returns also can do this by sending the 275.LF (in XML or in PDF) to the mail address

For additional information with respect to this Alert, please contact the following:

Ernst & Young Tax Consultants SCCRL/BCVBA, Brussels
  • Steven Claes
  • Herwig Joosten
  • Peter Moreau
  • Arne Smeets
  • Kurt Van der Voorde
  • Jan Bode
  • Pierre Legros
Ernst & Young Tax Consultants SCCRL/BCVBA, Antwerp
  • Werner Huygen
Ernst & Young LLP, Belgium-Netherlands Tax Desk, New York
  • Max Van den Bergh

EYG no. 06589-171Gbl