At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-26. Tax authority: FPS Finance (FOD Financiën / SPF Finances). Summaries are simplified; check the linked official source before relying on them.
The law
#The arm's length rule is in Article 185 §2 of the Income Tax Code 1992 (ITC 1992 or CIR 92). Article 26 (abnormal or gratuitous benefits) and Articles 49 and 207 also let the tax office challenge related party prices. Documentation duties are in Articles 321/1 to 321/7 ITC 1992, added by the Law of 1 July 2016 and changed several times since. Belgium follows the OECD Guidelines through a circular of 25 February 2020.
Documentation
#A Belgian entity or permanent establishment of a multinational group must file a local file (form 275.LF) and a master file (form 275.MF) if, in its stand-alone statutory accounts for the accounting year before the last closed one, it passed at least one of these tests: operating and financial income of EUR 50m (excluding non-recurring income), a balance sheet total of EUR 1bn, or an average of 100 full-time employees. Part B of the local file is only needed for a business unit whose cross-border related party transactions passed EUR 1m in the last closed year. The local file has the same deadline as the corporate income tax return. The master file is due 12 months after the end of the group's reporting period. Forms are filed in XML through MyMinfin. Royal Decrees of 16 June 2024 and 7 December 2025 changed the forms for accounting years starting on or after 1 January 2025. FPS Finance moved the 275.LF deadline for these new forms to 10 November 2026 because the new XML tool was late.
Methods
#OECD methods are accepted and the tax office follows the OECD most appropriate method approach. The 5% mark-up simplified approach for low value adding services is accepted. Belgian law does not require a full benchmark study to be filed, but all related party prices must be justified at all times.
Penalties
#Missing, late, incomplete or wrong master file, local file or CbC filings can bring an administrative fine under Article 445 ITC 1992 of EUR 1,250 for a first breach, up to EUR 25,000 for later breaches, and EUR 12,500 from the first breach if bad faith is shown. If information is missing, the tax office can adjust the tax base and the company then has to prove arm's length pricing. An error or gap in the local file can make the return incomplete, which opens the way to a tax increase of 10% to 200% (the 10% first-time increase is waived in good faith cases by the Program Law of 18 July 2025).
Pillar Two
#Belgium applies the QDMTT and the IIR to fiscal years starting on or after 31 December 2023 and the UTPR to fiscal years starting on or after 31 December 2024 (Law of 19 December 2023, amended since). Groups register once through MyMinfin for a Crossroads Bank for Enterprises number. Each year they file a GIR notification, a QDMTT return (11 months after year end), an IIR return and the GIR (15 months, or 18 months for fiscal years starting by 31 December 2024), and a UTPR return where it applies. On 28 September 2026 FPS Finance moved every QDMTT and IIR return and GIR notification whose legal deadline fell before 31 October 2026 to 31 October 2026. The GIR deadline itself was not moved. A bill approved in committee in October 2026 would move the QDMTT return to 15 months, but it was not law when checked.
Other rules
#Unilateral, bilateral and multilateral APAs and rulings are available through the Ruling Commission. Interest deduction is limited to the higher of 30% of tax EBITDA or EUR 3m. Groups that owe QDMTT or IIR top-up tax should in principle make advance payments, on the same dates as corporate income tax advance payments. For calendar 2025 year ends FPS Finance gave a general extension of the corporate income tax return to 15 October 2026.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC notification (form 275.CBC.NOT) Due by the last day of the group's reporting period. Since the reporting period ending 31 December 2024 it is no longer annual: file only a first notification, a change, or an end of the obligation (for example after leaving the group, falling below EUR 750m or liquidation). For 31 December 2025 year ends FPS Finance moved the deadline to 28 February 2026. | Last day of the fiscal year (e.g. Dec 31, 2025) | Belgian entities of a group with consolidated gross revenue of at least EUR 750m in the previous reporting period. | FPS Finance: BEPS13 e-service news (275.LF and 275.CBC.NOT deadlines) |
| 2 | Corporate income tax return (Biztax, vennootschapsbelasting / impôt des sociétés) By law the return is due on the last day of the 7th month after year end. For year ends from 31 December to the end of February, FPS Finance sets a later date each year: it announced 30 September 2026 for these year ends and then extended it to 15 October 2026 (10 October in 2025, 7 October in 2024). A deadline on a Saturday, Sunday or public holiday moves to the next working day. Individual extensions are only for serious reasons or force majeure. | Extended: FPS general extension for 2025 returns (15 October 2026) (e.g. Oct 15, 2026); original due date Sep 30, 2026 | All Belgian resident companies and Belgian permanent establishments and branches of foreign companies (non-resident corporate tax). | FPS Finance: Délais de rentrée des déclarations (Biztax) |
| 3 | Local file (form 275.LF) Same deadline as the corporate income tax return. For the new form (accounting years starting on or after 1 January 2025), FPS Finance moved the deadline to 10 November 2026 and will not charge a tax increase or fine for a 275.LF filed by then; the return itself must still be filed on time. The date shown is never before 10 November 2026 for December to March year ends. | Extended: FPS one-time extension to 10 November 2026, no penalty if filed by then (e.g. Nov 10, 2026); original due date Sep 30, 2026 | Belgian entities and permanent establishments of a multinational group that, in their stand-alone statutory accounts for the accounting year before the last closed one, had operating and financial income of EUR 50m or more (excluding non-recurring income), OR a balance sheet total of EUR 1bn or more, OR an average of 100 full-time employees or more. Part B is needed only for a business unit whose cross-border related party transactions passed EUR 1m. Only the income test is used for the date tool. | FPS Finance: BEPS13 e-service news (275.LF and 275.CBC.NOT deadlines) |
| 4 | QDMTT return (domestic top-up tax return) and payment Due on the last day of the 11th month after year end (Article 52 of the Pillar Two Law), so 30 November 2026 for calendar 2025. FPS Finance moved returns for fiscal years ending by 31 October 2025 to 31 October 2026. A bill approved in committee would change this to 15 months (18 for years starting by 31 December 2024); it was not law when checked. | 11 months after year end (e.g. Nov 30, 2026) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years that have Belgian entities. Required even if no top-up tax is due and even if the transitional CbC safe harbours apply. | FPS Finance: Pillar 2 returns (QDMTT and IIR) |
| 5 | Master file (form 275.MF) Due within 12 months after the last day of the group's reporting period, so 31 December 2026 for a calendar 2025 group year. Filed in XML through MyMinfin. A new form applies to accounting years starting on or after 1 January 2025. | 12 months after year end (e.g. Dec 31, 2026) | Same tests as the local file: EUR 50m operating and financial income, OR EUR 1bn balance sheet total, OR 100 average full-time employees, in the stand-alone statutory accounts for the accounting year before the last closed one. Only the income test is used for the date tool. | FPS Finance: Prix de transfert - BEPS 13 |
| 6 | Country-by-country report (form 275.CBC) Due within 12 months after the last day of the group's reporting period (Article 321/2 ITC 1992). Filed in XML through MyMinfin. | 12 months after year end (e.g. Dec 31, 2026) | Belgian ultimate parent of a group with consolidated gross revenue of at least EUR 750m, or a Belgian entity that must file locally (for example when the parent country does not exchange the report). | FPS Finance: Prix de transfert - BEPS 13 |
| 7 | GIR notification Each group entity, or one designated Belgian entity for all, says which entity files the GIR. Due before the matching GIR deadline. FPS Finance moved it to 31 October 2026 for fiscal years ending by 31 March 2025 (years starting by 31 December 2024) or by 30 June 2025 (years starting from 1 January 2025), so the date is never before 31 October 2026. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | FPS Finance: Notification of the GIR filing entity |
| 8 | GloBE Information Return (GIR) Due 15 months after year end, or 18 months for the first year (30 June 2026 for calendar 2024). FPS Finance kept this legal deadline and did not extend it. Not needed locally if filed in a country that exchanges it with Belgium. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | FPS Finance: Pillar 2 e-service news (GIR deadline maintained) |
| 9 | IIR top-up tax return Due on the last day of the 18th month for fiscal years starting by 31 December 2024 and the 15th month for later years (Articles 57 and 57/1). FPS Finance moved returns for years ending by 31 March 2025 (starting by 31 December 2024) or by 30 June 2025 (starting from 1 January 2025) to 31 October 2026. | 15 months after year end (e.g. Mar 31, 2027) | Belgian parent entities of in-scope groups (consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years). | FPS Finance: Pillar 2 returns (QDMTT and IIR) |
| 10 | UTPR return Assumed to follow the GIR timing (15 months), which gives 31 March 2027 for calendar 2025. FPS Finance consulted on a draft UTPR return in June 2026 and the final form and date were not confirmed, so check before relying on it. | 15 months after year end (e.g. Mar 31, 2027) | In-scope groups with Belgian entities subject to the UTPR, for fiscal years starting on or after 31 December 2024. A return is needed even if no UTPR tax is due. | KPMG Belgium: Belgian draft UTPR top-up tax return |
| 11 | Pillar Two registration (notification form, Crossroads Bank for Enterprises) One-time notification through MyMinfin so the group gets a Crossroads Bank for Enterprises number, needed for later filings and advance payments. Due 30 days after the start of the first fiscal year in scope; groups already in scope had until 45 days after the Royal Decree of 15 May 2024 was published (29 May 2024). | See note | Groups with at least one Belgian entity within the Pillar Two rules (consolidated revenue of at least EUR 750m in two of the four previous fiscal years). The Belgian ultimate parent files, or the Belgian entity if the parent is abroad, or one appointed entity. | FPS Finance: Pillar 2, register with the Crossroads Bank for Enterprises |
| 12 | General representative designation (MyMinfin) A general representative files the joint QDMTT return for all Belgian entities. The appointment must be notified through MyMinfin before the QDMTT return is filed. | See note | Groups with more than one Belgian entity subject to the QDMTT or the UTPR. | FPS Finance: Pillar 2 deadline extension of 28 September 2026 (point 3, general representative) |
Official texts
#- Income Tax Code 1992 (Fisconet+ and Justel / Moniteur belge) (Official acts of public authority are not protected by copyright in Belgium (Code of Economic Law, art. XI.172 §2). No passages are quoted because the current consolidated wording of the ITC 1992 could not be read from an official page (Justel's copy is out of date and Fisconet+ could not be read).)