Circular on the implementation of minimum taxation

The Belgian Tax Authorities (i.e., FPS Finance) issued Circular 2025/C/68 (NL / FR) on the implementation of minimum taxation for multinational enterprises and large domestic groups in Belgium.

The circular provides guidance on the criteria for determining the entities subject to these rules, the calculation methods for the Top-up Taxes and the general compliance requirements, in line with the international rules. Accordingly, the circular is primarily based on the ‘Consolidated Commentary to the Global Anti-Base Erosion Model Rules’ and the ‘Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) Examples’ of the OECD as published on 25 April 2024, as well as the ‘Frequently Asked Questions on Pillar 2 Directive’ of the EU.

While the Circular is quite extensive, it does not really include new insights regarding the application and interpretation of the minimum taxation rules. At the same time, a draft law amending the Belgian Law on minimum taxation is pending with the Belgian Parliament and the Belgian Tax Authorities are yet to provide more guidance about the DMTT compliance requirements. Considering the quickly approaching filing deadline for DMTT, more information is expected shortly in respect of DMTT compliance. See also our previous news item:  Changes to the Belgian Law on Minimum Taxation - KPMG Belgium

KPMG can assist businesses in navigating the complexities of the global minimum taxation. Our team of experts can provide guidance on compliance requirements and help you to identify the relevant data points, gather the required data and perform the calculations for both the DMTT and jurisdictional Top-up Tax liabilities (i.e., IIR and UTPR). If you have any questions or need assistance, please contact your trusted KPMG advisor or reach out to us directly.