The Belgian Tax Authorities have published, for public consultation, the draft UTPR top-up tax return and accompanying explanatory notes (see: NL / FR). Stakeholders are invited to submit their feedback by 3 July 2026 via e-mail to pillar2@minfin.fed.be.
The draft UTPR top-up tax return and the explanatory notes concern assessment year 2025. Under the Belgian Law on Minimum Taxation (Pillar 2) the UTPR top-up tax applies to fiscal years beginning from 31 December 2024. The filing deadline for the UTPR top-up tax return is aligned with that of the information return (the Belgian equivalent of the GIR/TIR) and is, in principle, the last day of the 15th month following the end of the fiscal year. Where the fiscal year coincides with the calendar year, this means that the first filing deadline is 31 March 2027.
In Belgium, the UTPR top-up tax return is a formal tax return and triggers the issuance of an assessment notice by the Belgian Tax Authorities.
As a general reminder, the first filing deadline of the information report (GIR/TIR) is 30 June 2026, whereas the GIR notification deadline has recently been postponed to 30 September 2026, as announced by the Belgian Tax Authorities. For further details, see our previous news items: GIR notification deadline and IIR return template and Pillar 2 compliance formalities in Belgium.
How can KPMG help you?
KPMG can assist you with all compliance aspects of the global minimum tax 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 all top-up taxes.
If you have any questions regarding the applicable rules and their implications for your business, or if you require assistance with the Belgian minimum tax, please do not hesitate to contact your trusted KPMG advisor or reach out to us directly.
