Country-By-Country Reporting (Cbcr)
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Country-by-Country reporting (CbCr)
Country-by-country file 275 CBC (NL) / Country-by-country file 275 CBC (FR) The 275 CBC form needs to be prepared and submitted to the Belgian tax authorities within 12 months as of the last day of the financial year; The 275 CBC form is to be filed with the jurisdiction of the ultimate parent entity of a group. However, if the jurisdiction of the ultimate parent entity of a group has not yet implemented any CbCr legislation or if no automatic exchange mechanisms are in place, the obligation for filling the CbCr with respect to FY 2016 will be shifted to the next tier parent entity; Notification form 275 CBC NOT (NL) / Notification form 275 CBC NOT (FR) to be completed and submitted to the Belgian tax authorities within 12 months after the first day of the financial year, but for the first time before September 30, 2017 for accounting years starting on January 1, 2016
Notification form
Insofar the CbCr does not have to be completed by the Belgian entity, the Notification form 275 CBC NOT is to be submitted to the Belgian tax authorities; Notification form 275 CBC NOT (NL) / Notification form 275 CBC NOT (FR) to be completed and submitted to the Belgian tax authorities within 12 months after the first day of the financial year, but for the first time before September 30, 2017 for accounting years starting on January 1, 2016
Every qualifying Belgian group entity that is member of an MNE group needs to prepare a Master file and Local file when one of following criteria is exceeded in its statutory financial accounts in the prior year: • Gross operating and financial income equal to or exceeding EUR 50M • Total balance sheet equal to or exceeding EUR 1 billion • Average annual number of 100 FTE
Master file
Master file 275 MF (NL) / Master file 275 MF (FR) The Master File should be submitted to the Belgian tax authorities within 12 months after the end of the financial year
Local File
Local File 275 LF (NL) / Local File 275 LF (FR) Part I: A1-A8: to be filed together with the Belgian corporate tax return for assessment year 2017 Part II: B1-B12 to be filed with the corporate tax return for assessment year 2018 This detailed form will only be required for the business units of the Belgian entity of which the cross border transactions exceed an amount of €1 million in the last accounting year
Background info
The Federal Public Service Finance provides for additional information: an overview of all transfer reporting requirements, an overview of the BEPS 13 requirements (NL) / overview of the BEPS 13 requirements (Dutch / French).
As the digital forms are not yet available, the forms can be sent:
By e-mail to: [email protected] or
By regular post to: FOD Financiën Algemene Administratie van de Fiscaliteit Administratie Grote Ondernemingen Centrum GO Beheer en Gespecialiseerde Controles Afdeling Sectorcoördinatie Kruidtuinlaan 50 bus 3354 1000 Brussel