Belgian Transfer Pricing Documentation

Belgian Transfer Pricing Documentation

The transfer pricing documentation structure proposed by the OECD has been adopted by Belgium.


In line with the guidance provided by the OECD in Action Point 13 of its Base Erosion and Profit Shifting (BEPS) reports, Belgium did introduce transfer pricing documentation requirements through the Program Law of July 1, 2016 and the related Royal Decree dated October 28, 2016.

By doing so, Belgium is moving from an era where no transfer pricing documentation was being required (unless requested in the context of a tax audit), to a formal transfer pricing documentation obligation which includes the electronic filing of the documentation to be prepared.

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