by Joke Gysens, Yannick Cools, Febe Louage and Sarah Keulemans
On June 1, the Belgian tax administration published the final declaration form for the Qualified Domestic Minimum Top-up Tax (QDMTT). This marks an important step in the continued implementation of Pillar 2 regulations in Belgium.
For multinational corporate groups and large domestic groups, the QDMTT return will now become an annual obligation. This declaration obligation applies even if no top-up tax is ultimately due.
The final form conforms to the international GloBE standards and collects information on, among other things:
the identification of the Belgian entities and the group;
the application of any safe harbours
choices made and calculations of the top-up tax;
relevant financial and tax data.
With the publication of the final form, the compliance obligation becomes concrete and the first filing deadline is fast approaching.
For groups whose first reporting year starts between 01/01/2024 and 30/09/2025, the filing deadline was exceptionally extended to September 30, 2026.
For fiscal years ending later in 2025, the standard deadline of 11 months after the close of the fiscal year will in principle apply. For calendar year taxpayers, for example, this means a filing deadline of Nov . 30, 2026.
The QDMTT return requires a thorough analysis of your group structure, available data and calculations under the Pillar 2 regulations. Timely preparation will not only help you mitigate compliance risks, but also maximize potential benefits, such as safe harbors.
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Joke Gysens
Senior Manager International joke.gysens@vdl.be
Yannick Cools
Director Corporate Tax yannick.cools@crowevdl.be
Febe Louage
Senior Manager International febe.louage@vdl.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.
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