Belgian DMTT-return template

The Belgian Tax Authorities (i.e., FPS Finance) published on their website the draft template of the Belgian Domestic Minimum Top-up Tax (DMTT), which is available in Dutch and French. While no further changes are expected to this template, this version is for information only, and the official (final) version will be published in the Belgian Official Gazette. Previously, the draft return was subject to public consultation in October 2024 and has undergone few modifications to arrive at the current template. The Tax Authorities also indicated that they will soon release the XSD-schema and a guidance for the completion of the DMTT-return.

The calculation of the Belgian DMTT is generally aligned with that of the Jurisdictional Top-up Tax, including e.g., the de minimis exclusion and the transitional CbCR safe harbour rules. Accordingly, the Belgian DMTT is considered to be a Qualified DMTT based on the OECD’s central record.

The Belgian Tax Authorities aimed at aligning the DMTT-return template with that of the OECD GIR-template, but also limiting its scope to information which is required for the DMTT. The DMTT-return consists of the following main sections:

1. Identification (of the Belgian entities, the Designated Local Entity; and the MNE-group)
2. Group structure
3. Safe harbours
4. Elections
5. DMTT computation
6. Prepayments
7. DMTT liability
8. Contact person
9. Signature

The first filing deadline for the (Q)DMTT in Belgium is 30 November 2025 (i.e., last day of the 11^th month following the fiscal year). This deadline is seven months before the first GIR-return filing deadline for FY2024, and one month before the CbCR-filing deadline. This may imply additional compliance burden and the calculation of the temporary safe harbors with non-final CbCR data.

The DMTT-return can only be submitted if the Group is registered for Pillar 2/GloBE purposes in Belgium. The registration requirements as well as the facilities for making prepayments were introduced last year.

KPMG can assist you with all compliance aspects of the Pillar 2/GloBE minimum taxation in Belgium and worldwide, including registration, calculation of tax liabilities and filing of returns for both the DMTT and the jurisdictional Top-up Taxes (i.e., IIR and UTPR). Additionally, we can also help you to identify the relevant data points, gather the required data and perform the calculations for both the (Q)DMTT and jurisdictional Top-up Tax liabilities.

If you have questions or need any assistance, do not hesitate to reach out to your trusted KPMG advisor or contact us.