The Belgian tax authorities have communicated that the online MyMinfin platform is not available due to technical reasons till the beginning of December 2020 to submit CBC-files (form 275CBC or CBCNOT).
Belgian legal entities, branches and taxable permanent establishments that are part of a multinational group with a consolidated gross revenue of EUR 750 million or more (or an equivalent in a foreign currency) (during the financial year preceding the financial year most recently closed) have to meet CbCr obligations, i.e. Country-by-Country notification (CbC notification or form 275 CBCNOT) or Country-by-Country Report (CbC report or form 275CBC) in case of the ultimate parent company or local filing. The submission date for these documents is no later than on the last day of the financial year of the Belgian entity (including branches and taxable permanent establishments) respectively no later than 12 months after the last day of the group’s reporting period concerned. The submission obligations for form 275CBCNOT should be nuanced as, from 31 December 2019 (or later), this will only be required if the information to be provided differs from the information that was provided in respect of the previous reporting period.
From a practical perspective, companies whereby the financial year is aligned with a calendar year, the due date of the CBC-files is 31 December 2020. If the Belgian tax authorities are able to deal with their technical problems in a timely manner, we do not assume any extension of the submission dates for the CBC-files.
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