Prepayments for the Pillar Two IIR Top-up Tax

The Belgian Tax Administration (i.e., FPS Finance) has announced that the approach for advance payments of the IIR top-up tax, in the context of minimum taxation (i.e., Pillar Two), will change as of 2026 (see: NL / FR ). Entities subject to IIR top-up tax that choose to make advance payments will be required to make the prepayments at the entity level (i.e., as opposed to the group level). This means that, for payment transfers, the entity must either use the structured communication available on its MyMinfin-portal or generate this communication via the tool provided by FPS Finance.

This change applies only to advance payments of the IIR top-up tax. For advance payments of the domestic top-up tax (DTT) the current procedure remains unchanged (see: Prepayment system for P2 minimum taxation operational - KPMG Belgium ).

The above change in approach aligns with the underlying concept of the Pillar Two top-up taxes, according to which the IIR top-up tax is levied at entity level and the DTT is levied at jurisdictional level. 

KPMG can assist you with all compliance aspects of 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 DTT 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 the Belgian minimum taxation, please do not hesitate to contact your trusted KPMG advisor or reach out to us directly.