2026 Outlook: Revised Transfer Pricing Documentation requirements now in effect

The Belgian transfer pricing legislation requires taxpayers to complete and submit specific transfer pricing documentation forms, consisting of the Local File, the Master File, and the CbC notification form. The requirement applies annually to Belgian entities and permanent establishments of multinational groups that meet the applicable thresholds.

In recent years, the Belgian tax administration has amended the forms for financial years starting on or after 1 January 2025. A Royal Decree issued on 16 June 2024 (“Royal Decree 2024”) replaced the earlier 2016 version, followed by a subsequent decree dated 7 December 2025 (“Royal Decree 2025”). While the Royal Decree 2024 introduced additional detail regarding the information to be reported, the Royal Decree 2025 recalibrates the manner in which information is provided to the tax authorities.

As we are 2026 and the first filing deadlines approach, it is time to look back at these developments and assess the requirements going forward.

What has changed?

Local File (Form 275 LF)

A key change for the revised Local File form under the Royal Decree 2025 is that taxpayers are no longer obliged to attach to the form, the transfer pricing studies and intercompany agreements in readable PDF format. Taxpayers must still disclose the availability of such documentation within the form itself and may choose to submit it voluntarily where relevant.

Apart from this, the following amendments introduced under the Royal Decree 2024 have been retained:

• Provision of a breakdown of the intercompany transaction amounts per country for each business unit with cross‑border transactions exceeding EUR 1 million.
  
  
• Disclosure of the transfer pricing method applied, per transaction, per business unit and per country.
  
  
• Cost contribution agreements, advance pricing agreements, rulings, and intragroup (re)insurance agreements must be attached in a readable PDF format.
  
  
• Inclusion of Tax Identification Numbers (TIN) of the competitors of the Belgian entity's (and its foreign permanent establishments, if any)
  
  
• In the section concerning cost contribution agreements, advance pricing agreements, rulings and in-house (re)insurance policies, indication of the country code and TIN number instead of the company number.

Master File (Form 275 MF)

No changes were introduced under the Royal Decree 2025. The enhanced requirements issued under the Royal Decree 2024 therefore continue to apply in full. The Belgian transfer pricing requirements for the Master File remain broader than the OECD baseline, particularly due to the obligation to include the actual figures of the intragroup transactions for all group entities and align them with the TP policies.

The following information must be included in order to meet the Belgian Master File compliance requirements for 2025:

• A detailed value chain analysis and functional analysis (in 4 steps), including:
  
  • Listing of the several value drivers, 
  • Mapping the principal contributors to those value drivers, 
  • Allocation of the profits amongst the group entities, 
  • comparison and alignment with transfer pricing outcomes.
    
    
• A Development, Enhancement, Maintenance, Protection, Exploitation (DEMPE) analysis (in 6 steps) for intangible assets.
  
  
• Information on Hard-To-Value Intangibles (‘HTVI’) that have been transferred or used during the reporting period.
  
  
• A more detailed description on the group's transfer pricing policies for financing arrangements.

CbC notification (Form 275 CBC NOT)

The requirements for the CbC notification form remain as introduced under the Royal Decree 2024 and now explicitly requires taxpayers to indicate whether the filing constitutes a first notification, a modification or a termination of the obligation.

Following the late publication of the new XSD schema of the form on 1 December 2025, the Belgian tax administration granted a filing extension until 28 February 2026 for groups with a 31 December 2025 year-end.

Timely preparation is key

Transfer pricing continues to be a key focus for Belgian tax authorities and 2026 is shaping up to be an important year to review the current transfer pricing policies. Companies will need to demonstrate that the data they report is fully reliable, that their transfer pricing policy is presented in a clear and coherent narrative, and that they submit complete and carefully prepared forms. Failure to comply with the new requirements may result in inaccurate or incomplete filings, thereby exposing taxpayers to potential administrative penalties.

Contact

At Grant Thornton, we are pleased to put our expertise at your disposal to assess whether your organisation is ready to meet the new requirements and to support you in preparing accurate and coherent forms. We help you turn these obligations into an opportunity to structure, enhance and secure your transfer pricing model in anticipation of tax audits.

To explore what the above changes to the Belgian forms would mean for your business, please reach out to your usual Grant Thornton advisor.