Transfer pricing documentation

Preparing your business for imminent new reporting obligations

Belgian entities of foreign- or Belgian-headquartered multinational groups with annual revenues exceeding 50 million euros need to start preparing their business for transfer pricing documentation obligations that recently have been introduced. Given the increased scrutiny, it’s also imperative to check the consistency of transfer pricing arrangements with actual conduct.

The rules are being introduced to:

  1. increase transparency on multinational groups’ intercompany transactions
  2. allow tax authorities to more effectively conduct transfer pricing investigations
  3. assess the correctness of transactions in the broader international context
  4. instigate moral behaviour to reduce international tax planning


Three layers of transfer pricing documentation are being introduced in Belgium


Layer 1- Transfer Pricing documentation

The OECD’s country-by-country reporting (CBCR). The threshold of 750 million euros consolidated revenues for completing and filing is expected to be maintained. It’s recommended to already start putting the necessary processes in place to collect and produce CBCR data and test whether systems are adequately equipped to handle or automate CBCR. 

A Masterfile covering information relevant to the entire group of companies (subject to the aforementioned 50 million euros threshold)

Step 3 transfer pricing documentation | PwC Belgium

A Local File and tax return form including detailed information about an individual entity’s inter-company transactions (subject to the aforementioned 50 million euros threshold).

On 1 July 2016, the Belgian Parliament adopted the ‘programme law’ (introduced on 2 June 2016) that contains the introduction into Belgian tax law of specific transfer pricing documentation requirements (published in the Belgian Official Gazette of 4 July 2016). The Masterfile and Local File obligations are implemented as from financial years starting on or after 1 January 2016, expanded with a tax return form obligation identifying intercompany transactions and counterparties. The Royal Decrees covering the implementation measures of the newly adopted documentation requirements are being drafted. It is expected that these implementation measures will be finalised by the end of September or early October 2016.

Interpreting these obligations at a practical level can be extremely complex.

How we can help

We’re fully versed on all aspects of the field and the impact the legislation will have on your organisation.

Our Belgian team of more than 50 full-time transfer pricing experts use proven documentation approach to helping clients comply with obligations in the most efficient manner. 

The PwC transfer pricing team is at your service. Find a local expert.

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