Belgium has adopted the transfer pricing documentation structure proposed by the Organisation for Economic Cooperation and Development (OECD).
In line with guidance provided by the OECD under Action 13 of the base erosion and profit shifting (BEPS) project, Belgium introduce transfer pricing documentation requirements in a 1 July 2016 "program law" and by the related Royal Decree (dated 28 October 2016).
Belgium, thus, is moving from an era when no transfer pricing documentation was required (unless requested in the context of a tax audit), to a formal transfer pricing documentation regime that includes the electronic filing of documentation.
Read a January 2017 report [PDF 1.9 MB] prepared by the KPMG member firm in Belgium
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.