As previously discussed in our earlier articles on the reporting obligation for payments to tax havens (“Payments towards tax havens – new administrative circular & updated country list” and “Payments towards tax havens – wake-up call for non-compliant companies” ), Belgian companies must remain vigilant when making direct or indirect payments to entities established in listed jurisdictions.
The reporting obligation (Form 275F) applies to payments of at least 100.000 EUR per taxable period to entities located in jurisdictions included on the Belgian tax haven list. Non-compliance can have significant consequences: payments that are not properly reported maybe disallowed, irrespective of their economic substance. This can potentially result in specified tax audits, additional tax assessments and penalties.
Experience shows that the Belgian tax authorities are increasingly stepping up their audit activity in this area, with specific attention to cross-border payments and the proper completion of Form 275F.
The Belgian tax haven list has been updated for 2025, e.g. Malta disappeared from the list, but Vietnam appeared on it. Companies should verify whether their counterparties are located in one of the listed jurisdictions and assess whether reporting obligations apply.
Download the updated 2025 tax haven country list (Excel): click here.
If you would like to analyse the impact on your organisation, do not hesitate to contact your trusted HLB advisor.