The Belgian Tax Authorities have released explanatory guidance on the templates for both the domestic top-up tax return and the IIR top-up tax return. In addition, an FAQ covering the filing of the domestic top-up tax return and the general representative has been published. Key information on these recent developments is summarized below.
Explanatory guidance for top-up tax returns
Following the earlier publication of the templates for the domestic top-up tax (DTT) return and the IIR top-up tax return (see: GIR notification deadline and IIR return template), the explanatory guidance to these templates has also been made available on the website of the Belgian Tax Authorities. Accordingly, the authorities announced that all relevant documentation for filing these tax returns is available, see NL / FR.
As a reminder, the filing deadline of the DTT and the IIR top-up tax returns is 30 September 2026 (see: Extended deadline for DMTT return and IIR top-up tax return filing).
FAQ on DTT return and general representative
A FAQ regarding the filing of the domestic top-up tax return, as well as regarding the general representative in the context of the domestic top-up tax and the UTPR top-up tax is published by the Belgian Tax Authorities: FAQ | FOD Financiën / FAQ | SPF Finances.
This FAQ clarifies the procedural rules for filing the DTT return, including the implications where a group has more than one Belgian entity subject to the DTT in Belgium.
The FAQ further elaborates on the mandatory designation and notification of the general representative. This concept applies where an MNE group has more than one entity in Belgium that is subject to the DTT and the UTPR top-up tax (hereafter: liable Belgian entities). The general representative acts in its own name as well as on behalf of all liable Belgian entities, assuming all obligations and exercising any rights provided under the Belgian Law on Minimum Taxation. In effect, it serves as a single procedural point of contact in dealings with the Belgian Tax Authorities (e.g., filings, queries, and assessments).
A general representative must be one of the liable Belgian entities of the MNE group. It must be designated by these entities and notified to the Belgian Tax Administration on an annual basis. The notification deadline corresponds to the earliest deadline for the top-up tax returns or the information return. If no general representative is notified, the tax administration will identify the general representative based on the statutory cascading rules determined in the Belgian Law on Minimum Taxation. The notification must be submitted via the MyMinfin portal before the first applicable filing deadline.
How can KPMG help you?
While the concept of a general representative was introduced into Belgian law in December 2025 (see: Fiscal year-end topics and tips), the recently published FAQ specifies that notification is, in principle, mandatory. This requirement constitutes an additional compliance obligation for taxpayers. However, the practical implications of this obligation remain to be fully understood given the current context (specifically the imminent GIR deadline, the extended deadline for top-up tax returns, and the unavailability of the portal for notifying the general representative).
If you have any questions regarding the above developments, 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.
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.
