Transfer pricing documentation 2026: deadlines and requirements

When are a local file and master file required?

The submission of a local file and master file is mandatory if your Belgian entity is part of a multinational group and exceeds at least one of the following thresholds during the financial year preceding the reporting year:

• turnover of EUR 50 million;

• an average workforce of 100 FTEs;

• a balance sheet total of EUR 1 billion.

The assessment is based on the statutory financial statements of the Belgian company for the most recently closed financial year.

Local file deadline for financial year 2025

In Belgium, the local file must, in principle, be submitted by the same deadline as the corporate income tax return or the non-resident corporate income tax return.

For entities whose financial year coincides with the calendar year, the filing deadline for financial year 2025 was originally set at 30 September 2026, together with the corporate income tax return.

However, due to changes to the form resulting from the expanded content requirements, a general extension was granted. The new deadline for submitting the local file is 10 November 2026.

Please note: the filing deadline for the corporate income tax return remains unchanged.

Master file deadline for financial year 2025

The master file must be submitted no later than 12 months after the last day of the group’s reporting period.

For groups whose financial year ends on 31 December, this means that the deadline for financial year 2025 is 31 December 2026.

Stricter transfer pricing documentation requires timely preparation

Expanded documentation requirements have applied since financial year 2025. In our previous article on the new transfer pricing documentation requirements in Belgium, we discussed these changes in detail.

The substantive changes represent a significant tightening of the documentation requirements. For the master file, the Belgian requirements also go beyond international requirements. As a result, companies in Belgium are often required to provide more information than in other countries.

These stricter requirements call for a thorough analysis of the group-level transfer pricing policy and, where necessary, additional information to be included in the existing master file documentation.

It is therefore important for your company to have a robust and fully developed transfer pricing policy that complies with the OECD Guidelines. This should be supported by a high-quality and comprehensive local file and master file.

The stricter transfer pricing documentation requirements in Belgium are not a temporary trend but part of a structural international development in the fight against tax evasion.

Transfer pricing is receiving increasing attention during tax audits

Tax authorities worldwide are paying increasing attention to transfer pricing. This is reflected in legislative, administrative and judicial developments.

In Belgium, the transfer pricing documentation requirements have been reformed and audit capacity has been strengthened, including through the expansion of the specialised transfer pricing unit. At the same time, the tax authorities are applying their penalty policy more strictly. This highlights the importance of accurate documentation and sound substantiation of intragroup transactions.

Transfer pricing also remains a topical issue internationally. This is illustrated, among other things, by the recent Stellantis Portugal judgment (C-603/24), in which the Court of Justice ruled on the relationship between transfer pricing adjustments and VAT.

These developments confirm that transfer pricing remains an important area of attention for companies and their tax compliance obligations.

Companies that underestimate these requirements or treat transfer pricing documentation as a mere formality expose themselves to significant tax and financial risks. With the deadlines approaching, it is therefore advisable to start preparing the transfer pricing documentation for financial year 2025 as soon as possible.

Country-by-country reporting (CbCR), public EU CbCR and Pillar Two

In addition to the local file and master file, additional requirements apply to groups with consolidated annual operating revenue of at least EUR 750 million.

Multinational groups with Belgian entities that exceed this threshold are subject to both CbC and Pillar Two requirements. Pillar Two requirements may also apply to multinational groups operating exclusively in Belgium.

The main deadlines are as follows:

• Country-by-country report (CbCR): no later than 12 months after the last day of the group’s reporting period.

• Country-by-country reporting notification: no later than the last day of the group’s reporting period.

• Public country-by-country report: no later than 12 months after the last day of the group’s reporting period.

• Pillar Two domestic top-up tax return: no later than 11 months after the last day of the group’s reporting period.

For the Pillar Two domestic top-up tax return, the reporting period for financial year 2024 remains open until 30 September 2026. The deadline for financial year 2025 is also fast approaching and falls on 30 November 2026.