Adjustment to the Belgian Local File Form

On 19 December 2025, a new Royal Decree of 7 December 2025 was published replacing the Royal Decree of 16 June 2024, amending the model Local File Form (“275 LF”) (article 321/5, § 4 of the Belgian Income Tax Code).

While the Royal Decrees of 16 June 2024 announced amendments to the Local File Form, Master File Form and CbCR Notification Form, the new Royal Decree of 7 December 2025 reverses some of the earlier announced changes in relation to the Local File Form, while the changes for the Master File Form and CbCR Notification Form remain valid. The changes, imposed by the Royal Decrees of 16 June 2024 and 7 December 2025, are applicable for qualifying taxpayers with respect to financial years starting on or after 1 January 2025.

Background

With reference to the guidance provided by the OECD in Action Point 13 of the Base Erosion and Profit Shifting (BEPS) framework, Belgium had introduced transfer pricing compliance requirements through the Program Law of 1 July 2016, and the related Royal Decree dated 28 October 2016.

A Local File Form and Master File Form should be filed by each Belgium company or permanent establishment (of a multinational group) which exceeds one of the following thresholds (to be assessed based on the standalone financial statements of the Belgian taxpayer – company or permanent establishment – for the preceding financial year):

• A sum of operational and financial income of EUR 50 million (excluding non-recurring income);
• A balance sheet total of EUR 1 billion; or
• An annual average of employees of 100 full-time equivalents.

The Local File Form should be filed as part of the corporate income tax return on the specific electronic platform of the Belgian tax authorities. The filing due date corresponds to the filing date of the corporate income tax return. The Master File Form should be filed with the Belgian tax authorities within a period of 12 months after the close of the reporting period of the group.

A CbCR Notification Form needs to be filed by each Belgian constituent entity which is part of a group that falls under the CbCR requirements. The CbCR Notification Form must be filed by the end of the group’s reporting period. The CbCR Notification does not need to be filed annually if no changes have occurred since the last filing.

The Royal Decrees of 16 June 2024 announced amendments to the Local File Form, Master File Form and CbCR Notification Form as introduced by the Program Law of 1 July 2016. We refer to our previous Tax Flash in this respect.

Royal Decree 7 December 2025

The Royal Decree of 7 December 2025 reverses some of the earlier announced changes in relation to the Local File Form, while the changes for the Master File Form and CbCR Notification Form remain valid. The main changes to each form are described below:

Local File Form (275 LF)

While the new model form of 275 LF remains largely similar to its predecessor, there is one significant change to note:

• When a transfer pricing methodology or policy document, and/ or framework agreement or model contract, and/ or transfer pricing study is available, the Belgian taxpayer only needs to indicate in table B10 of the form whether these documents  are readily available, without having to proactively submit/attach the documents in a readable PDF format to the Local File Form as was instructed by the Royal Decree of 16 June 2024.

Despite this change, other modifications to the Local File Form remain applicable. This includes the following:

• A detailed overview of the intercompany transactions per business unit is required to be provided separately per country rather than on an aggregated jurisdictional basis.
• When cost contribution agreements, advanced pricing agreements, advance decisions (rulings) and intercompany re-insurance agreements are in place, these documents need to be attached to the Local File Form in a readable PDF format.
• Some minor adaptations require that the Tax Identification Numbers should be included of the Belgian organizational structure (shareholders and participations), competitors of the Belgian entity, as well as the Tax Identification Number(s) for the foreign Permanent Establishment(s) of the Belgian entity. In addition, the country code relating to cost contribution agreements, advance pricing agreements, rulings and in-house (re)insurance policies should also be indicated, as well as the Tax Identification Number(s) of the counterparties.

Master File Form (275 MF)

The new Royal Decree does not modify the 275 MF, the additional information to be included in the Master File Form as established in the Royal Decree of 16 June 2024 remains applicable. This includes the following, all of which extend beyond the documentation requirements under the OECD TP Guidelines:

• A description of the analytical framework for the value chain and functional analysis of the group following a four-step methodology (e.g., listing the value drivers, mapping the principal contributors, allocation of the profits, comparison and alignment with transfer pricing outcomes). This additional information requires a more detailed value chain and functional analysis, which goes beyond the requirements included in the OECD TP Guidelines.
• An elaborated description of the DEMPE functions relating to intangibles needs to be disclosed in the Master File Form. This includes a detailed analytical framework for the DEMPE functions, also including a list of the group’s transferred or exploited Hard-to-Value Intangibles.
• For the transfer pricing policies relating to financing arrangements, a more detailed description of the financial policies and transactions is requested, including information on financial guarantees, analysis of captive insurance companies, etc.

CbCR Notification Form (275 CBC NOT)

The new Royal Decree does not modify the announced changes from the Royal Decree of 16 June 2024. While the CbCR Notification Form has not changed significantly, entities are required to indicate if the submitted form is a first notification, modification of previous notification, or termination of a notification obligation.

KPMG Observations

Local File Form

Ensure to review and update your transfer pricing documentation processes in light of the revised requirements. Particular attention should be paid to distinguishing between documents that must be attached to the Local File Form and those for which it is sufficient to indicate their existence. While the proactive submission of transfer pricing methodologies, policy documents, framework agreements, model contracts, and transfer pricing studies is no longer mandatory, maintaining robust and contemporaneous transfer pricing documentation and agreements remains critical. These documents serve as a primary line of defense in the event of a transfer pricing audit and substantiate the arm’s length nature of intercompany transactions.

Master File Form

The revised Master File Form imposes more extensive and analytical disclosure requirements than those set out in the OECD Transfer Pricing Guidelines, particularly with respect to value chain analysis, DEMPE functions, and financing arrangements. As non-Belgian headquartered companies typically attach the Master File prepared by the group to the Belgian Master File Form, one may need to review whether modifications to the group Master File could be required (as from 2025) in order to be compliant with these new regulations. In this respect we recommend adding an appendix to the Belgian Master File Forms to ensure compliance with the Belgian specific requirements, as requesting the foreign head-office to adjust the group Master File directly might be challenging.