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Belgium: Civil penalties for transfer pricing documentation compliance failures

Belgium: Penalties for transfer pricing documentation

A Royal Decree (published in the official gazette in July 2018) establishes the civil penalties to be imposed for failures to comply with the transfer pricing documentation requirements.


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In 2016, Belgium implemented the OECD’s base erosion and profit shifting (BEPS) Action 13 concerning transfer pricing documentation. Companies that meet certain thresholds are required to file specific documentation or forms—such as the Master file, Local file, country-by-country (CbC) report, and CbC reporting notification (articles 311/1 to 321/6, introduced by law of 1 July 2016). 

Taxpayers that fail to satisfy the reporting and filing requirements for transfer pricing documentation will be subject to civil penalties that range from €1,250 (for a second infringement) to €25,000 (for five or more infringements). 


Read a July 2018 report prepared by the KPMG member firm in Belgium

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