Further extension for filing the domestic top-up tax return and IIR (Pillar 2)
by Febe Louage, Joke Gysens, Yannick Cools and Sarah Keulemans
Since 1 January 2024 (reporting years starting on or after 31 December 2023), the minimum tax for multinationals and large domestic groups (Pillar 2) has been in effect. Groups with a consolidated turnover of at least 750 million euros in at least two of the four preceding reporting years must pay a minimum tax of 15%. The minimum tax rate of 15% is ensured through three mechanisms: the Qualified Domestic Minimum Top-up Tax (QDMTT), the Qualified Income Inclusion Rule (IIR), and the Qualified Undertaxed Profits Rule (UTPR).
In summary:
New filing deadline: 30 September 2026
Applies to groups with a first financial year between 01/01/2024 and 30/09/2025
Applicable to both QDMTT and IIR returns
One-off extension for the first filing
The GIR (GloBE Information Return) deadline remains, for now, 30 June 2026
In an earlier article (Minimum tax for multinationals), we provided an overview of the obligations in Belgium. This clarified that the QDMTT return must be filed on the last day of the eleventh month following the end of the reporting year. For groups with a reporting year ending on 31 December 2024, this means that the first return would have to be filed no later than 30 November 2025.
On 17 November 2025, an important update was announced: the Belgian tax administration is granting an extension for the submission of the first QDMTT return.
Deadline update
On 3 April 2026, the Belgian tax authorities published a new update regarding the domestic top-up tax return. An additional extension is now granted for filing the domestic top-up tax return until 30 September 2026.
This extension applies to groups whose first reporting year ends between 1 January 2024 and at the latest on 30 September 2025.
Please note: this is a one-time extension. For subsequent financial years, the original deadline of eleven months after the end of the financial year remains applicable.
What about other levies?
The deadline for the IIR top-up tax is also extended until 30 September 2026 (inclusive).
However, the deadline for the GloBE Information Return (GIR) remains set at 30 June 2026. The GIR is the reporting framework that underpins the calculations under Pillar 2.
Why an extension?
The final version of the QDMTT return has not yet been published. In this context, the Belgian administration has therefore decided to grant additional time.
The administration’s announcement also states that practical guidelines and technical documentation regarding the filing procedure will be provided at a later date.
Despite the extension, we advise taxpayers to continue with their preparations and start collecting the necessary information to ensure a smooth filing process later on. Groups falling under the permanent or temporary safe harbours must also file a QDMTT return in Belgium.
Questions or need assistance? Our international tax experts are ready to help.
This form can only be sent with the use of technical cookies. You can accept these cookies here.
These cookies are used to distinguish people from bots. Certain data, such as your IP address or language preference, can be sent to Google. More information in our cookie policy.
Febe Louage
Senior Manager International febe.louage@vdl.be
Joke Gysens
Senior Manager International joke.gysens@vdl.be
Yannick Cools
Corporate Tax yannick.cools@crowevdl.be
Sarah Keulemans
Senior Tax Advisor sarah.keulemans@vdl.be
Disclaimer
In our opinions, we rely on current legislation, interpretations and legal doctrine. This does not prevent the administration from disputing them or from changing existing interpretations.
News and insights
Read our latest insights and news releases to stay abreast of changes in your industry.
