The transfer pricing compliance requirements of Belgian taxpayers include the filing of a Local file, Master file and Country-by-Country (CbC) notification and report. The Local and Master files are required to be filed if the taxpayer meets any of the following tests:
- Total operating and financial revenues (excluding non-recurring items) of EUR 50 million or more;
- Balance sheet total of EUR 1 billion or more; or
- Average annual number of employees of 100 FTEs or more.
The Local file forms …