On 9 October 2025, the Belgian government submitted to Parliament a draft law introducing technical amendments to the law of 19 December 2023 (the “Pillar 2 Law”), which implemented a minimum tax for multinational enterprises (MNEs) and large domestic groups.
What is included in the draft law?
The proposed changes to the Pillar 2 Law are primarily aimed at clarifying the Pillar 2 rules and do not include any technical changes to the calculations. They can be summarised as follows:
- Technical Clarifications: the draft law does not alter the calculation of the minimum tax but clarifies certain definitions such as “group” and “joint venture”. In addition, the draft law explicitly states that joint ventures and joint venture affiliates are in scope of the Belgian QDMTT.
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Appointment of a Group representative:
- If the group has multiple Belgian entities, one of them should be appointed as the representative, responsible for the compliance requirements for the Belgian QDMTT and Belgian UTPR, including the actual payment.
- When no notification is done, the general representative will be, by default, the entity filing the QDMTT return or GloBE Information Return. If no return is filed, the representative is considered (in this order): 1) the Belgian Ultimate Parent (“UPE”) Company, 2) if there is no Belgian UPE, the Belgian holding company having an ownership interest in all Belgian companies, 3), in case the first and the second situations do not apply, the Belgian entity with the highest total balance (based on the statutory financial accounts)
- The appointment should be communicated on the respective e-platform.
- Reduction of assessment period: the period for tax audits and assessments is reduced from 10 to 6 years, except in cases of fraud.
- Tax returns vs. information return: the proposed changes distinguish the Belgian QDMTT return and the Belgian IIR/UTPR return which qualify as tax returns and for which assessment notice(s) will be issued (jointly in case of multiple Belgian entities for the QDMTT and UTPR), from the GloBE Information Return (GIR) which does not qualify as a tax return but an information return.
What is next?
- The draft law is currently being reviewed by the Belgian Parliament and is expected to be adopted in the coming months.
- Note that the draft law does not include any changes to the deadline of the first Belgian QDMTT return which is still expected to be 11 months after the end of the financial year, i.e. 30 November 2025 for calendar year taxpayers. Today, the Belgian QDMTT return is still draft, and we are still expecting updates with respect to the final version. Please also refer to our previous news alert on the draft return.
Authors
Pieter Deré, Partner
Evi Geerts, Partner
Maxim Allart, Director
