Opening portal for top-up tax return submissions in Belgium

The Belgian Tax Authorities opened the portal for the submission of the domestic top-up tax return, the IIR top-up tax return and the notification of the general representative on 1 July 2026. As previously announced, the deadline for the submission of these returns is 30 September 2026 (see: Extended deadline for DMTT return and IIR top-up tax return filing). Key information on the current situation regarding Global Minimum Tax (Pillar Two) compliance obligations is summarized below.

More specifically, the following filings can now be made via the MyMinfin portal:

1. Domestic top-up tax (DTT) return for fiscal years 2024 and 2025.
2. IIR top-up tax return for fiscal years 2024 and 2025
3. Notification of the general representative.

The relevant documentation for filing these tax returns and the notification of the general representative has been made available earlier by the Belgian Tax Authorities (see: Pillar 2 compliance developments in Belgium).

The notification of the filer of the GloBE Information Return (GIR notification) must be submitted by 30 September 2026 for assessment years 2024 and 2025 (see: GIR notification deadline and IIR return template ). Further information regarding the opening of the portal and filing arrangements for the GIR notification are yet to be communicated.

Due to the late opening of the portal for the GloBE Information Return (GIR / TIR), it is expected the the Belgian Tax Authorities will be lenient in applying late filing penalties (see: Opening portal for GloBE Information Return submission). In fact, the Belgian Tax Authorities are said to dismiss such penalties if the GIR is submitted by 30 September 2026. However, there has been no official communication in this respect from the authorities yet.

If a group has more than one entity in Belgium, the concept of a general representative applies for the purposes of the DTT and the UTPR top-up tax. In such cases, the Belgian entities are required to appoint a general representative and notify this appointment annually to the Belgian tax authorities. An FAQ regarding the general representative, including the formalities and the notification requirement, has recently been published by the authorities. (see: Pillar 2 compliance developments in Belgium).

Based on the FAQ, the general representative must be an entity that is subject to the same top-up tax as the represented entities for the relevant fiscal year and must be appointed by these entities through a power of attorney. The power of attorney must be provided to the authorities only upon request, and no official template is available. As the general representative assumes all rights and obligations provided by the Belgian Law on Minimum Taxation (in relation to the DTT and UTPR top-up tax) and acts as the single procedural point of contact in dealings with the Belgian tax authorities, it is advisable to clearly detail its role and liabilities vis-à-vis the other Belgian entities of the group in the power of attorney.

The general representative must be notified annually to the Belgian tax authorities. This notification is separate from both the GIR notification and the registration notification. While the Law on Minimum Taxation provides cascading rules where the general representative is not appointed or notified, it is understood that non-compliance with the notification obligation may trigger penalties. The notification of the general representative must be submitted in XML format.

Considering the role of the general representative, it is advisable to determine which entity will act as general representative before submitting a DTT return. If the general representative needs to be changed, this can be done by submitting a new notification of the general representative.

If you require assistance with the Belgian minimum tax or have questions about the applicable rules and their implications for your business, please do not hesitate to contact your trusted KPMG advisor 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.