Extended Belgian DMTT-return filing deadline

The Belgian Tax Authorities have announced an extension to the filing deadline for the Domestic Minimum Top-up Tax (DMTT) return through administrative tolerance (NL / FR). The first filing deadline for the DMTT returns is now extended until 30 June 2026. Accordingly, the deadline is aligned with that of the GloBE Information Return (GIR) / Top-up Tax Information Return (TTIR). This is a welcome measure as it gives MNE groups more time to perform the required calculations and organize the filing process. 

Under the Belgian Law on minimum taxation, the deadline for filing the DMTT return is the last day of the 11th month following the end of the fiscal year (see: Belgian DMTT-return template - KPMG Belgium ). Accordingly, for fiscal year 2024, the first filing deadline would have been 30 November 2025 (i.e., where the fiscal year coincides with the calendar year). This deadline is seven months before the first GIR/TTIR return filing deadline and one month before the CbCR filing deadline. 

As a result of the extension, the first filing deadline for the DMTT return is 30 June 2026. More concretely, this deadline applies to DMTT return with respect to fiscal years:

• that begin on 31 December 2023 or later, and
• that end no earlier than 1 January 2024 and no later than 30 June 2025.

In effect, this means that the new filing deadline for all DMTT returns with an initial due date before 30 June 2026, is now 30 June 2026. This first deadline is aligned with the global rules and, accordingly, allows MNE-groups to meet their compliance obligations at once for the purposes of all filing obligations under Pillar Two/GloBE. 

The extension is not entirely unexpected, as the final DMTT return template has not yet been published and the Belgian Tax Administration’s portal is not yet open for DMTT return submissions.

Furthermore, a draft law was recently submitted to the Belgian Parliament, introducing key compliance aspects into the Law on minimum taxation (e.g., general representative; see: Changes to the Belgian Law on Minimum Taxation - KPMG Belgium). This draft law must be adopted before further administrative measures can be implemented.

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

If you have any questions regarding the applicable rules and their implications for your business, or if you require assistance with Belgian minimum taxation, please do not hesitate to contact your trusted KPMG advisor or reach out to us directly.