The Belgian tax authorities have published technical documentation on the GloBE information return (see: NL / FR / EN). The documentation mainly consists of OECD materials regarding the GloBE information return (GIR) and the exchange of information, but it also includes additional Belgian validation rules. However, these validation rules are still in draft form and remain subject to the transposition of DAC9 (Council Directive (EU) 2025/872 of 14 April 2025) into Belgian law. Accordingly, the documentation is shared for information purposes only and cannot be regarded as final.
GIR filing deadline
Based on the Belgian Law on Minimum Taxation, the deadline for filing the GloBE information return is the last day of the 15th month following the end of the fiscal year. However, the first filing deadline is extended to the last day of the 18th month following a fiscal year that begins no later than 31 December 2024. Accordingly, the first filing deadline is 30 June 2026.
At the same time, the Belgian tax authorities have recently granted, by way of administrative tolerance, an extension to the filing deadlines for both the Domestic Minimum Top‑up Tax (DMTT) return and the IIR top‑up tax return. See: Extended deadline for DMTT return and IIR top-up tax return filing. However, this extension does not apply to the GIR filing deadline.
Approaching filing deadlines amid remaining uncertainties
The first filing deadline is fast approaching. At the same time, DAC9 on the exchange of information between EU Member States has not yet been transposed into Belgian law, leaving it uncertain how the criteria for centralised filing will be applied. In addition, the final technical documentation for filing top‑up tax returns has not yet been published by the Belgian tax authorities. Further developments in this respect are expected shortly.
How can KPMG help you?
The rapidly approaching deadline, combined with uncertainties regarding the concrete terms and procedures for complying with the filing requirements, creates additional complexity. If you have any questions about the applicable rules and their implications for your business, or if you require assistance with the Belgian global minimum tax rules, please do not hesitate to contact your usual KPMG adviser or reach out to us directly.
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.
