Belgium - Local Requirements – Aibidia

Source:

Income Tax Code 1992 (ITC 1992), Article 321/4 (Master File) and Article 321/5 (Local File), as inserted by the Programme Law of 1 July 2016 (Belgisch Staatsblad / Moniteur Belge of 4 July 2016, pp. 40981–40982)
Royal Decree of 16 June 2024 (Belgisch Staatsblad / Moniteur Belge N. 151 of 15 July 2024), as amended by the Royal Decree of 7 December 2025 (Belgisch Staatsblad / Moniteur Belge of 19 December 2025)

Summary of local requirements

Strict Format: Yes, Form 275 LF (for Local File) and Form 275 MF (for Master File)

Language: Dutch, French, German or English

To download the legislation in the original language, go to:

Form 275 LF ("Local File")

Management structure of the Belgian company (A1)	Describe the departments/divisions/sections of the Belgian company and the name of the manager of each department/division/section. Include both legal and operational structure. Minimum description of management and managerial staff. If extensive, include in separate PDF and refer in the text box. Schematic representation can be included in section C1 'Other documents', in PDF form.
Belgian organisation structure - shareholders or head office (A2)	Complete the Belgian legal structure one level higher. Include tax identification number and direct shareholders or head office. Schematic representation can be included in section C1 'Other documents', in PDF form.
Belgian organisation structure - shareholdings (A3)	Belgian legal structure one level lower. Include tax identification number and direct shareholdings over which the company has direct control. Schematic representation can be included in section C1 'Other documents', in PDF form.
Belgian reporting structure (A4)	Include the reporting structure within the Belgian company and from the Belgian company towards foreign countries. Describe the management level (Board of Directors, CFO, CEO, etc.). If no Belgian reporting structure exists, indicate at least the 5 highest positioned employees.
Activities (A5)	Include the most important activities or functions of the Belgian company.
Most important competitors (A6)	Include the most important sector partners or competitors of the Belgian company.
Key data (A7)	Key data of the Belgian company including ultimate parent entity, reporting structure, foreign head office, and foreign permanent establishments. Include details on restructurings as specified.
Overview of transactions, both related and unrelated, (A8)	Include full figures of the company for last financial year (BT-0) and two preceding years (BT-1 and BT-2). Provide operational result figures as per accounting legislation definitions.
Detailed information about each business unit (B1)	Identify business unit, NACEBEL code, profile, and detail profile. Include more explanation in section C1 'Other documents' if necessary.
Transaction details, both related and unrelated, per business unit (B2)	Provide information as indicated in A7 but split according to business units. Indicate accounting standard applied.
Related cross-border goods transactions per business unit (B3)	Indicate transactions per business unit and per country code. Choose applied method for determining transfer prices.
Related cross-border service provision transactions per business unit (B4)	Indicate transactions per business unit and per country code. Choose applied method for determining transfer prices.
Related cross-border financial transactions per business unit (B5)	Indicate transactions per business unit and per country code. Choose applied method for determining transfer prices.
Other related cross-border transactions per business unit (B6)	Include other transactions not specified above. Indicate transactions per business unit and per country code. Choose applied method for determining transfer prices.
Transfer price methodology and studies per business unit (B10)	Refer to requirements in local file as per OECD BEPS action plan 13. Include framework agreements or model contracts in PDF.
Cost contribution agreements, advance pricing agreements, rulings (B12)	Add available documents in readable PDF.
Other documents (C1)	Optional box to provide additional details in PDF for better interpretation of the local file.

Recommendations for Local File:

Regarding content requirements:

Management Structure with Department Heads:

Belgium requires a description of the departments/divisions/sections of the Belgian company and the name of the manager of each department/division/section, including both legal and operational structure (Section A1).

We recommend preparing a detailed management structure document describing each department/division/section with the corresponding manager names, to be included in the Management Structure subsection of the Entity Description section or uploaded as a schematic PDF in section C1 (Other documents) from the Resources section of TPDoc.
Three-Level Organizational Structure:

Belgium requires three separate organizational charts: (A2) shareholders or head office one level higher, (A3) shareholdings one level lower, and (A4) reporting structure.

We recommend preparing these three organisational charts showing the Belgian company's position within the group structure, with tax identification numbers for all entities, and uploading them in section C1 from the Resources section of TPDoc.
Business Unit Segmentation:

Belgium requires detailed information for each business unit, including NACEBEL code, profile, and transaction details split by business unit (Sections B1-B6).

We recommend documenting each business unit separately in TPDoc's Reporting Level structure, ensuring each reporting level corresponds to a distinct business unit with its specific NACEBEL classification and transaction profile.
Country-by-Country Transaction Reporting:

Belgium requires that related cross-border transactions in sections B3-B6 (goods, services, financial, and other transactions) must be reported per business unit AND per country code, with the applied transfer pricing method indicated for each.

We recommend preparing detailed transaction schedules disaggregated by business unit and by country of the related party counterparty, documenting the transfer pricing method applied to each country relationship, to be compiled from TPDoc's Reporting Level sections organised by business unit and counterparty jurisdiction.
Competitors' Tax Identification Numbers:

Belgium's updated Form 275 LF of 27 January 2026 requires the TIN of the Belgian entity's key competitors to be provided, including for any foreign permanent establishments.

We recommend identifying the TIN for each key competitor listed in section A6 and entering this information in the Main Competitors section of TPDoc.
Transfer Pricing Documentation and Mandatory PDF Attachments:

Following the Royal Decree of 7 December 2025 and the updated Form 275 LF of 27 January 2026, taxpayers are no longer required to attach full TP studies, methodology descriptions, or framework agreements to section B10 of Form 275 LF. Taxpayers must confirm on the form whether such documentation exists and may voluntarily attach it in section C1. The following remain mandatory PDF attachments in section B12: cost contribution agreements (CCAs), advance pricing agreements (APAs), other tax rulings, and intragroup (re)insurance policies.

We recommend maintaining comprehensive OECD-compliant transfer pricing documentation in TPDoc and ensuring it is readily available for submission to the Belgian tax authorities upon audit request. Mandatory PDF attachments (CCAs, APAs, rulings, and intragroup (re)insurance policies) should be uploaded in the Legal Agreements section of TPDoc and attached to section B12 of Form 275 LF at the time of filing.

Regarding format/structural requirements:

Belgium imposes a strict standardised XML format for the Local File using Form 275 LF, with the current model form published on 27 January 2026 following the Royal Decree of 7 December 2025, effective for financial years starting on or after 1 January 2025.

Form 275 LF consists of three main parts: (A) General information about the Belgian company (8 sections), (B) Detailed information per business unit (12 sections covering business units, transactions by type and country, and transfer pricing methodologies), and (C) Other supporting documents.

The Form 275 LF must be completed using the official Belgian tax authority tool available at https://eservices.minfin.fgov.be/ to convert documentation into the required XML file format before submission.

We recommend preparing comprehensive OECD-compliant transfer pricing documentation using TPDoc's Local File functionality, particularly for the substantive content required in Part B of Form 275 LF (business unit analysis, functional analysis, transaction descriptions, comparability analysis, and method selection). Subsequently, use the prepared TPDoc documentation to populate the official Belgian Form 275 LF tool. Given the complexity of Belgium's business unit segmentation requirements, country-by-country transaction reporting, TIN disclosure obligations, and mandatory PDF attachment requirements for section B12, it may be advisable to engage a Belgian tax advisor to ensure full compliance with Form 275 LF completion and XML conversion requirements.

Form 275 MF ("Master File")

I. Organizational Structure	Diagram illustrating the legal and ownership structure of the multinational group as well as the geographical location of operating entities.
II.Description of the Business Domain(s) of the Multinational Group	General written description of the activities of the multinational group including: -Description of the analytical framework for the value chain and functional analysis of the group concerning the following stages: Stage 1: Determination of the important sources of benefits of the enterprise ('value drivers') and their relative importance; Stage 2: Determination and mapping of the principal contributions of the different entities of the group to value creation (including a written functional analysis, i.e., the key functions performed, significant risks assumed, and important assets used); Stage 3: Attribution of benefits to individual entities on the basis of value creation for each principal function; Stage 4: Comparison and alignment with transfer pricing results. -Description of the supply chain for the five principal goods and/or services offered by the group (classified by turnover) as well as any other goods and/or services representing more than 5% of the group's total consolidated turnover. The description may take the form of a diagram or chart; -List and brief description of important service agreements between group entities, other than R&D services, including a description of the capabilities of the principal sites providing important services and transfer pricing policies applied for allocating service costs and determining prices invoiced for intra-group services; -Description of the principal geographical markets for the goods and services of the group referenced in the second point of this enumeration; -Description of important business reorganization operations as well as acquisitions and asset disposals occurring during the taxable period.
III. Intangible Assets of the Multinational Group (as defined in Chapter VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations = TPG)	General descriptionof the global strategy of the multinational group regarding the development, enhancement, maintenance, protection and exploitation of intangible assets (DEMPE), notably the location of principal R&D facilities and the management of R&D activities. Description of the analytical framework for DEMPE functionsrelating to intangible assets concerning the following stages (see paragraph 6.34 TPG): Stage 1: Identification of intangible assets and risks associated with DEMPE; Stage 2: Identification of all contractual agreements with particular emphasis on determining the legal ownership of intangible goods and contractual rights and obligations, including risks contractually assumed in the relations between associated enterprises; Stage 3: Identification of parties that exercise DEMPE functions, through functional analysis, and identify in particular which parties control any externalized functions and control specific risks and economically significant risks; Stage 4: Confirmation of the existence of consistency between the conditions of relevant contractual agreements and the behavior of parties, and determination whether the party assuming economically significant risks controls the risks and possesses the financial capacity to assume the risks linked to DEMPE; Stage 5: Identification of controlled transactions linked to DEMPE in light of legal ownership of intangible assets, other relevant contractual relationships and behavior of parties, including their respective contributions in terms of functions performed, assets employed and risks assumed; Stage 6: If possible, determination of arm's length prices for these transactions, based on contributions of each party in terms of functions performed, assets used and risks assumed. List of intangible assetsor categories of intangible assets of the multinational group that are important for establishing transfer prices, as well as entities that are their legal owners and entities exercising a DEMPE function in respect to these intangible assets. List of hard-to-value intangibles(HTVI) transferred or used by the multinational enterprise group, including a reference to the definition and characteristics of these HTVI (see paragraphs 6.189 and 6.190 TPG) as well as entities that are their legal owners and entities that participated in the creation of these HTVI. List of important agreements between associated enterprises relating to intangible assets, including cost-sharing arrangements, principal research service agreements and license agreements. General description of the group's transfer pricing policies relating to R&D and intangible assets. General descriptionof all important transfers of intangible asset interests between associated enterprises during the taxable period considered, mentioning the entities, countries and corresponding remuneration.
IV. Intercompany Financial Activities of the Multinational Group	General description of the manner in which the group is financed, including important financing agreements concluded with independent lenders of the multinational group. Identification of all entities of the multinational group exercising a central financing function for the group, including the country of incorporation of the considered entities and the location of their effective management seat. General description of the multinational enterprise's transfer pricing policy relating to financing agreements between associated enterprises, containing at least the following elements (as defined in Chapter X "Guidelines on transfer pricing relating to financial transactions" TPG): Description of the application of principles for identifying commercial or financial relations to financial transactions; Determination of arm's length conditions for treasury activities, including intra-group loans, centralized treasury management and hedging operations; Examination of financial guarantees; Analysis of captive insurance companies.
V. Financial and Tax Position of the Multinational Group	Consolidated annual accounts of the multinational group for the taxable period considered if they are prepared elsewhere for financial, legislative, internal management, tax or other purposes. List and brief description of existing unilateral advance pricing agreements (rulings) and other tax agreements concerning the allocation of income between countries.

Recommendations for Master File:

Regarding content requirements:

Four-Step Value Chain and Functional Analysis:

Belgium now requires a more detailed description of the value chain in four steps, with a particular focus on profit allocation (step 3).

We recommend preparing a comprehensive four-step value chain analysis that explicitly addresses profit allocation mechanisms across the group. This enhanced value chain documentation should be included in the Supply Chain section of TPDoc, with particular emphasis on documenting how profits are allocated across different entities based on their value contributions.
Enhanced Functional Analysis:

Belgium requires functional analysis with enhanced focus on value contribution and profit allocation, going beyond the standard OECD functional analysis framework.

We recommend preparing detailed functional analysis in the Functional Analysis section of TPDoc that explicitly links functions, assets, and risks to value creation and profit allocation, ensuring the analysis demonstrates how the profit split aligns with value contributions across the group.
Hard-to-Value Intangibles:

Belgium's updated explanatory notes incorporate additional guidance from the 2022 OECD Transfer Pricing Guidelines, particularly with respect to hard-to-value intangibles.

We recommend providing enhanced documentation for hard-to-value intangibles in the Intangible Assets section of TPDoc, including ex-ante and ex-post valuation considerations, projected versus actual outcomes, and the valuation methodology for intangibles that are difficult to value at the time of the transaction.
Financial Transactions:

Belgium's updated requirements reflect additional guidance on financial transactions from the 2022 OECD Transfer Pricing Guidelines.

We recommend documenting financial transactions with enhanced analysis in the Financing Arrangements section of TPDoc, addressing accurate delineation of financial transactions, functional analysis of financing activities, and arm's length remuneration for financial arrangements.

Regarding format/structural requirements:

Belgium imposes a strict standardised XML format for the Master File using Form 275 MF, as prescribed by the Royal Decrees of 16 June 2024 effective for financial years starting on or after 1 January 2025.

Form 275 MF structure remains consistent with Annex I to Chapter V of the OECD Transfer Pricing Guidelines, covering five mandatory categories: (1) Group organizational structure, (2) Description of the group's business, (3) Group intangibles, (4) Group intercompany financial activities, and (5) Group financial and tax positions.

The Form 275 MF must be completed using the official Belgian tax authority tool available at https://eservices.minfin.fgov.be/ to convert documentation into the required XML file format before submission.

We recommend preparing comprehensive OECD-compliant Master File documentation using TPDoc's standard Master File functionality, with particular attention to the enhanced requirements for value chain analysis (four-step framework with profit allocation), functional analysis emphasising value contribution, hard-to-value intangibles documentation per 2022 OECD Guidelines, and enhanced financial transaction analysis. Subsequently, use the prepared TPDoc Master File documentation to populate the official Belgian Form 275 MF tool, ensuring all content requirements specified in the expanded explanatory notes are addressed. Given the significantly enhanced content expectations beyond standard OECD Master File requirements, it may be advisable to engage a Belgian tax advisor to ensure full compliance with Form 275 MF completion and XML conversion requirements.