CbC Notification Requirements in Belgium: Action Required?

Belgian companies and permanent establishments that are/were part of a multinational group with consolidated turnover exceeding 750 million EUR must ensure compliance with Country-by-Country (CbC) notification requirements. Specifically, if the group’s financial year ends on 31 December 2025, Belgian entities need to assess whether a CbC notification is required — regardless of their own financial year-end.

A CbC notification must only be filed when:

1. It is the first notification.
2. There have been changes compared to the prior notification (e.g. information regarding the ultimate parent entity or the reporting entity).
3. The group no longer falls under the CbC reporting requirements.

Important Note: The CbC notification (form 275 CBCNOT) is not required annually but only in the above circumstances.

Hence, Belgian entities part of a multinational group with a financial year ending on 31 December 2025 for which the:

• consolidated turnover is exceeding 750 million EUR for the financial year per 31 December 2024; or
• consolidated turnover is no longer exceeding 750 million EUR for the financial year per 31 December 2024 (contrary to previous financial years)

absolutely need to ensure they verify whether a new CbC notification filing is required before the deadline of 31 December 2025.

UPDATE: the filing deadline of 31 December 2025 has exceptionally been extended to 28 February 2026.

In case of any questions, please reach out to your trusted HLB advisor, who can assist you with the necessary formalities.

Please do not wait until the very last week before the filing deadline, as a BEPS13 mandate may need to be activated first in order for HLB to be technically able to file the notification via the MyMinfin portal of the entity.