Since the 2024 tax year, the scope of the rules regarding Controlled Foreign Companies (CFC) has been significantly expanded. These regulations aim to tax undistributed passive income from certain foreign subsidiaries or entities of Belgian shareholder companies. The expansion has led to a complex set of rules. To provide more clarity on this matter, the tax authorities published a circular.

After lengthy negotiations, the Arizona coalition has finally reached a coalition agreement, documented in approximately 200 pages. This agreement includes several tax measures that could impact companies with cross-border activities.

Since 2016, Belgium has implemented a mandatory three-tier documentation system for transfer pricing, consisting of a master file, a local file and a country-by-country report (CbCR). For tax years beginning on or after 1 January 2025, these forms will be updated.