New guidance on the Belgian Transfer Pricing Form 275 CBC NOT

On 27 January 2026, the Belgian tax authorities issued updated guidance regarding the completion of the Country-by-Country Notification Form (“Form 275 CBC NOT”), required in the context of Country-by-Country Reporting (“CbCR”). This new guidance provides further clarifications following the Royal Decree of 16 June 2024, which amended the notification process for financial years starting on or after 1 January 2025.

The obligation to submit Form 275 CBC NOT applies to all Belgian constituent entities that are part of a Multinational Enterprise (“MNE”) Group meeting the CbCR requirements. As from 2019, this notification should no longer be submitted annually, but only if there has been a change compared to the information which was included in the latest Form 275 CBC NOT filed.

Following the Royal Decree of 16 June 2024, entities are required to specify the nature of the notification when filing Form 275 CBC NOT by selecting one of the following categories:

• A first notification;
• A modification of your previous notification; or
• A termination of your notification obligation due to no longer being part of the MNE Group.

However, it appeared there was uncertainty as to when each of the options should be selected in the Form 275 CBC NOT. To address this, the Belgian tax authorities have now issued additional guidance, specifically highlighting two scenarios. 

When a Belgian constituent entity becomes part of a different MNE Group (for example, due to an acquisition or other restructuring), a mandatory two-step procedure must be followed:

1. The Belgian constituent entity must first submit a Form 275 CBC NOT indicating the “termination of its notification obligation due to no longer being part of the MNE Group”, as it is no longer a member of the previous MNE Group. This step formally records the exit from the former MNE Group.
2. If the Belgian constituent entity joins a new MNE group that is also subject to CbCR requirements, it must then file a new Form 275 CBC NOT, hereby explicitly selecting the option “first notification” to reflect its entry into the new MNE Group.

The abovementioned two-step approach is required to clearly separate the obligations relating to the former and the new MNE group. As such, in this scenario, the option “modification of your previous notification” is not permitted.

If the consolidated revenue of an MNE Group drops below the EUR 750 million threshold, the obligation to file a Form 275 CBC NOT no longer applies. In such cases, all Belgian constituent entities, regardless of whether they are the ultimate parent entity or a subsidiary, must submit a Form 275 CBC NOT indicating the “termination of their notification obligation due to no longer being part of the MNE Group”. In such cases, “no longer being part of the MNE group” refers to the fact that the Group no longer meets the criteria for CbCR due to falling below the required revenue threshold. This administrative step formally closes the CbCR requirement for the Belgian entities involved.

In the published updated guidance, the Belgian tax authorities have also specified that the “modification of your previous notification” option may only be selected when the Belgian constituent entity remains within the same MNE group and the CbCR obligations continues to apply. This option is reserved for cases when there are changes to the previously reported information, such as changes to the address, name, or reporting entity.

Furthermore, although not included in the new guidance, we have received a confirmation from the Belgian tax authorities that in case of a liquidation of a Belgian constituent entity, a Form 275 CBC NOT needs to be filed for the reporting period of the group during which the liquidation occurred. In such case, the option “termination of your notification obligation due to no longer being part of the MNE group” needs to be selected.

These clarifications are particularly relevant as the deadline for submitting the Form 275 CBC NOT for financial years ending on 31 December 2025 has been extended to 28 February 2026. It is therefore important to take this guidance into consideration when determining whether one or more Forms 275 CBC NOT still need to be submitted before the deadline will pass. Our team of experts is ready to help you understand the implications and guide you through every step of the process.