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In a significant step towards implementing the OECD’s Pillar Two global minimum tax rules, Belgian tax authorities have published a draft version of the annual return that multinational enterprise (MNE) groups and large domestic business groups will be required to file under the national top-up tax regime, effective for financial years beginning in 2024.
The draft return, currently released for information purposes only, marks the beginning of Belgium’s compliance efforts with the OECD’s Global Anti-Base Erosion (GloBE) framework, which sets a global minimum effective tax rate of 15% for large corporate groups with consolidated revenues exceeding €750 million.
While the draft return is not yet legally binding, its release provides an early indication of the structure, scope, and reporting requirements that in-scope entities will face. The final version will gain legal force only upon publication in the Belgian Official Gazette, expected later this year.
Authorities have also confirmed that a technical XSD schema, necessary for digital submission of the return, will be made available in due course, alongside a comprehensive guidance document detailing how to complete the return. This is intended to provide clarity for taxpayers and advisors navigating the complex data reporting and reconciliation obligations under the new regime.
The introduction of the national top-up tax in Belgium follows broader European Union and OECD efforts to curb profit shifting and ensure that large corporations pay a minimum level of tax in jurisdictions where they operate. Once finalized, the return will be a critical component in demonstrating compliance and avoiding additional top-up liabilities.
Multinational and large national groups are encouraged to begin reviewing their internal reporting systems and engage with advisors to prepare for the first filing cycle in 2025. Although the current draft is not final, early familiarization with its structure could significantly ease the transition once the reporting obligations become mandatory.
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