Belgium implements technical amendments to its Pillar Two legislation

I. Overview

On 31 December 2025, the Belgian Parliament approved a bill making technical amendments to the Law of 19 December 2023 introducing a minimum tax for multinational enterprises and large domestic groups also referred to as Pillar Two.

The amendments as introduced by this bill are rather technical in nature and do not change the calculation of the Pillar Two tax as such. The adjustments are primarily intended to:

• Clarify the identification of taxpayers subject to the qualified domestic top-up (QDMTT) tax, including joint ventures and their affiliated entities;
• Establish joint and several liability when multiple entities of the same multinational group or large domestic group are present in Belgium;
• Facilitate interactions between group entities and the Belgian tax authorities by allowing them to appoint a representative.

For a more detailed overview, we refer to our previous Tax Alert¹.
 

II. Next steps

This bill paves the way to finalize and issue by Royal Decree the Belgian QDMTT return template. As a reminder, in-scope Pillar Two taxpayers are obliged to prepare and file a QDMTT return 11 months following the fiscal reporting year-end and thus, for the first time by 30 November 2025 for calendar year taxpayers. However, the Belgian Tax Authorities previously granted a general extension for all QDMTT returns whose statutory filing deadline falls before 30 June 2026, till 30 June 2026². We will inform you once the final template (and related guidance) is available.

Meanwhile, Pillar Two continues to be in full swing. At OECD level, a comprehensive package for a "side-by-side arrangement" with respect to the Pillar Two global minimum tax rules has recently been published, including the introduction of a side-by-side and UPE safe harbour, a permanent effective tax rate (ETR) safe harbour, the extension of the transitional safe harbors and new rules in relation to substance-based tax incentives. We would expect additional local legislative initiatives and additional guidelines to be required in order to apply these new elements in domestic legislation.

In case you need any assistance with the completion of your obligations under the Belgian Pillar Two legislation or more in general with Pillar Two related questions, please do not hesitate to reach out to us or to your dedicated person of contact.

¹ Belgium proposes technical amendments to its Pillar Two legislation

² Belgian QDMTT return deadline extended till 30 June 2026