According to recent reports, the Belgian government has drafted legislation for the implementation of the three-tiered transfer pricing documentation requirements developed under Action 13 of the OECD BEPS Project, including Country-by-Country (CbC) reporting, and Master file and Local file documentation requirements.
CbC Reporting
As drafted, the CbC reporting requirement would apply for MNE groups operating in Belgium with annual consolidated group revenue meeting a threshold of EUR 750 …