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Executive summary
On 30 October 2026, new legislation entered into force implementing the Council Directive (EU) 2025/872 of 14 April 2025 amending the EU Directive on administrative cooperation in taxation (“DAC9”) into Belgian law allowing for the GloBE Information Return (“GIR”) to be filed centrally and exchanged between EU tax authorities.
Furthermore, the new law introduces various amendments to Belgium’s Pillar Two legislation, including extending the statutory filing deadline of the Qualified Domestic Minimum Tax (“QDMTT”) return from eleven months to fifteen months after the end of the reporting fiscal year.
DAC9 framework for automatic exchange of GIRs
DAC9 introduces an EU framework for the exchange of GIR’s between Member States. Its objective is to facilitate centralized filing and the exchange of relevant information between the tax administrations concerned.
The new law transposes these DAC9 requirements into Belgian law and therefore further develops the Belgian administrative framework surrounding Pillar Two information reporting.
Under the approved DAC9 framework, the Belgian authorities will exchange the relevant sections of a GIR with other Member States according to a specific dissemination approach. This approach is intended to ensure that each jurisdiction receives only the information relevant to its Pillar Two taxing rights while limiting the exchange of unnecessary information.
In addition, a formal correction mechanism is introduced under which corrected GIRs need to be submitted following a request from the Belgian competent authority. Generally, a corrected filing needs to be made within one month following receipt of such request.
The first exchanges by Belgium under the implementation of the DAC9 framework would take place no earlier than 1 December 2026. Belgium will exchange information within three months as from the end of the submission deadline, or in case of a late submission within three months after receipt of the GIR.
While Belgium has now adopted DAC9, this does not by itself cover the exchange of Pillar Two information with jurisdictions outside the EU. Such exchanges may instead take place under a relevant Multilateral Competent Authority Agreement (“MCAA”).
In this respect, Belgium is taking steps to enable the exchange of GloBE information with jurisdictions outside the EU as on 9 October 2026, the Belgian Council of Ministers approved a preliminary draft law consenting to the MCAA.
Once entered into force, the Belgian tax authorities will be able to exchange GloBE information collected under the Belgian Pillar Two legislation with other relevant jurisdictions that have signed the agreement and for which it is in effect. The MCAA therefore complements the EU information-exchange framework under DAC9 by providing a mechanism for the exchange of GloBE information with relevant non-EU jurisdictions.
QDMTT filing deadline aligned with other Pillar Two filing deadlines
A key change relates to the filing deadline for the Belgian QDMTT return. The statutory deadline is extended from the last day of the 11th month to the last day of the 15th month following the end of the relevant fiscal year. A transitional rule applies to fiscal years beginning no later than 31 December 2024. For these fiscal years, the statutory deadline is the last day of the 18th month following the end of the fiscal year.
The purpose of the amendment is to harmonize the different filing deadlines currently contained in the Belgian Pillar Two legislation and to align them more closely with the timelines contained in the EU Minimum Tax Directive.
Practically, this implies that for calendar year-end taxpayers the 2025 statutory QDMTT filing deadline becomes 31 March 2027, i.e. 15 months after year-end, instead of 30 November 2026 under the previous 11-month rule.
Other amendments and clarifications
Besides the DAC9 transposition and the extension of the QDMTT return deadline, the law contains several other Pillar Two amendments.
- The law clarifies that the Belgian IIR and UTPR top-up taxes are subject to separate filing requirements. This is more of a technical/compliance clarification than a fundamental change to the charging provisions.
- The rules governing the general representative for Belgian Pillar Two purposes are adjusted to better align the legislation with the administrative guidance already issued by the Belgian tax authorities
- The legislation also addresses sanctions for Pillar Two compliance failures, including penalties for failures such as late/non-filing and incorrect or incomplete filings, with increased penalties in cases involving fraud or with the intent to cause harm.
- Finally, more generally, the amendments are intended to improve the readability of the Law of 19 December 2023 and bring it into closer alignment with the EU Pillar Two Directive.
Implications and next steps
The new law entered into force on 30 October 2026, which is the date of its publication in the Belgian Official Gazette.
Although the approved law focuses on the administrative exchanges between tax authorities under DAC9, the extension of the QDMTT filing deadline is likely to be the most immediately relevant development for many in-scope MNE groups.
Accordingly, the Belgian QDMTT reporting deadline will be aligned with other Pillar Two filing obligations, while providing additional preparation time. At the same time, the revised penalty framework illustrates the increasing importance of robust Pillar Two governance and compliance processes.
Groups with Belgian constituent entities should reassess their Pillar Two compliance calendars, reporting processes and filing responsibilities in view of the above changes.