The Belgian Tax Authorities have released several documents concerning the compliance formalities for the global minimum tax (Pillar 2), in light of the rapidly approaching first filing deadline for the GloBE Information Return. This documentation and related information concern, in particular, the domestic top up tax return, the GloBE Information Return, and an announcement regarding central filing. The key aspects are outlined below.
1. Domestic Top-Up Tax Return (DTT)
The DTT return template for assessment year 2024 was published in the Belgian Official Gazette on 1 June 2026 (see: Belgisch Staatsblad / Moniteur belge), followed by an announcement from the Tax Authorities (see: NL / FR) . There appear to be no differences compared to the draft DTT return previously published by the Belgian Tax Authorities (see our earlier news item: Belgian Draft Domestic Top-up Tax Return). The final explanatory notes have not yet been published but are expected to be released shortly.
The first filing deadline for the DTT return is 30 September 2026, following an administrative extension of the deadline (see our earlier news item: Extended deadline for DMTT return and IIR top-up tax return filing). The filing portal is not yet available at this time.
2. GloBE Information Return (GIR/TIR)
The formal release of the Belgian template for the GloBE Information Return is expected shortly and is anticipated to follow the OECD GIR template. The technical documentation (incl. the XSD schema and validation rules) was published earlier on the Pillar 2 e‑service portal of the Belgian Tax Authorities (see: Formulieren en tools | FOD Financiën). The validation rules contain two rules specific to Belgium (i.e., structure of the DocRefId and the structure of the MessageRefId).
The Belgian Tax Authorities also opened a simulation portal for GIR filings. Such a simulation can be filed through the Myminfin portal of the filing entity. This is particularly useful, given that the first filing deadline for the GloBE Information Return is fast approaching on 30 June 2026.
3. GIR/TIR Central Filing
The Belgian Council of Ministers has recently approved a draft law transposing DAC9 (Council Directive (EU) 2025/872) into Belgian domestic law and implementing further amendments to the Belgian legislation on minimum taxation. The draft law is expected to be adopted by the Belgian Parliament later this year.
In line with DAC9, the draft law provides exclusively for the automatic exchange of GloBE information between EU Member States. The rules governing the exchange of information with third countries outside the European Union are set out in the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), which is currently in the process of ratification in Belgium.
While the legislative process to enable central filing is still ongoing, the Belgian tax authorities have announced their commitment to enabling central filing in accordance with the OECD announcement of 18 May 2026. An announcement to this effect has been published on the Tax Authorities’ website on 8 June 2026: Pillar 2 - Common understanding of implementing jurisdictions on the central filing and the exchange of GloBE Information Return (GIR) | FPS Finance.
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.
