Pillar II: Filing Obligations in Belgium and Other Countries

Belgium transposed the EU requirements for implementing the global minimum tax through the Belgian law of 19 December 2023. Accordingly, multinational as well as Belgian corporate groups that meet or exceed the EUR 750 million revenue threshold are subject to the Belgian rules under Pillar II for financial years beginning after 30 December 2023.

Similar to the legal framework in Germany, Belgium has made use of the option provided in the EU Minimum Tax Directive to introduce a Qualified Domestic Minimum Top-up Tax (QDMTT).

A separate tax return for this Belgian QDMTT must be filed with the local tax authorities within eleven months after the end of a fiscal year. For fiscal years corresponding to the calendar year, this means the declaration for the 2024 financial year must be submitted by 30 November 2025.

The Belgian tax authorities have published a draft of the declaration form. Further guidance and an XSD schema are expected to follow shortly. The declaration requires extensive information, including details on the group structure, the calculation of the QDMTT, and the safe harbor provisions applied.

Note: Based on the current state of knowledge, it is assumed that the filing applies regardless of whether safe harbour provisions are applicable.

Corporate groups subject to Pillar II that have entities or permanent establishments in Belgium should begin preparing the necessary data for the QDMTT return as soon as possible to ensure timely compliance.

There is also urgent need for action under the Pillar II regulations in several other countries. For example, French-resident entities that are part of a corporate group falling under the global minimum tax rules are subject to a special reporting obligation, which must be fulfilled by 20 May 2025 for fiscal years aligned with the calendar year. Further details regarding the required disclosures and the formal requirements of the French tax authorities can be found here.

Furthermore, for corporate groups with at least one constituent entity in the United Kingdom, there is a registration requirement that must be met by 30 June 2025 for calendar-year filers.

The registration is conducted via an online portal of the UK tax authority and requires information about the UPE or other filing entity, whether the group has entities only in the United Kingdom or in both the United Kingdom and other jurisdictions, details of the authorised representative and the start and end dates of the accounting period.