Transfer pricing Belgium

If your company operates across multiple countries, you are required to comply with Belgium’s transfer pricing regulations. This means that costs, revenues, and profits must be correctly allocated to the jurisdictions in which your business is active. The Belgian tax authorities apply strict rules: you must be able to demonstrate that your intercompany transactions follow the arm’s length principle. Doing so helps you avoid reassessments, penalties, and double taxation.

As specialists in Transfer Pricing Belgium, we help businesses correctly apply these complex rules. We ensure that your intercompany transfer prices are fully substantiated and documented in line with Belgian requirements.

Comprehensive support for Transfer Pricing in Belgium

You can rely on our clear and expert guidance. We assist you with:

  • Determining the correct intercompany transfer prices;
  • Preparing all required transfer pricing documentation (Local File, Master File, CbCR if applicable);
  • Benchmarking studies to substantiate the arm’s length nature of your pricing;
  • Analysis of risks, tax implications, and compliance requirements.

With our support, you fully comply with Belgian transfer pricing regulations and ensure that your administration is well-documented and audit-proof.

Contact us

"*" indicates required fields

This field is for validation purposes and should be left unchanged.

Transfer Pricing in Belgium

Documentation Requirements at a Glance

General Requirements

  • Belgium has a three-tiered documentation requirement.
  • The regulations apply to financial years starting on or after 1 January 2016.
  • Documentation may be prepared in English but a translation into an official language may be requested during a tax audit.

Country-by-Country Report (CbCR)

  • Required for multinational groups with revenues over €750 million.
  • Must be filed within 12 months after the reporting period.
  • A notification must be sent to the Belgian tax authorities.
  • For financial years ending on or after 31 December 2019, notification is only required if changes occur.

Master & Local File Thresholds

  • Applies to entities in multinational groups exceeding at least one of the following:
  • Total operational and financial income: €50 million
  • Balance sheet total: €1 billion
  • Average number of employees: 100 FTEs

Forms & Deadlines

DocumentFormDeadline & Language
Country-by-Country ReportN/AWithin 12 months after period close
Master FileForm 275MFWithin 12 months after period close
Local FileForm 275LFFiled with tax return

Disclaimer

This information is based on secondary sources and provided for general informational purposes. Always confirm with a local advisor.

Avoid transfer pricing problems. Contact us today

Would you like more control over your transfer pricing position in Belgium? Or do you have questions about Belgian tax authority requirements?
Feel free to contact us for a no-obligation consultation.

Call us at +31 (0) 88 – 8 387 669,
email [email protected],
or fill out our contact form.

We provide clarity, certainty, and peace of mind, so you can conduct international business without tax concerns.

Get in touch

Amsterdam – Kleine-Gartmanplantsoen 21
Arnhem – Willemsplein 34-2
Breda – Ceresstraat 13
Nederland


DTS Duijn’s Tax Solutions B.V.
Bank: Rabobank
BIC: RABONL2U
IBAN: NL64RABO0167742167