Belgium: Pillar Two global minimum tax rules adopted by Parliament
Belgian Parliament adopted draft law on implementation of Pillar Two global minimum tax rules
Pillar Two global minimum tax rules adopted by Parliament
The Belgian Parliament adopted the draft law on implementation of the Pillar Two global minimum tax rules for multinational enterprises and large-scale domestic groups.
The law generally follows the EU Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022) and transposes the income inclusion rule (IIR) and undertaxed payment rule (UTPR) into Belgian legislation. Additionally, it incorporates the Belgian domestic minimum top-up tax (DMTT) and the transitional safe harbor rules, as well as implements changes to the Belgian research and development (R&D) tax credit. While it also generally incorporates the supplementary rules introduced by the Organisation for Economic Cooperation and Development (OECD) administrative guidance on the Pillar Two rules released in February 2023, the supplementary rules released in July 2023 will be included in a separate draft law, amending the current law.
The law will become effective 31 December 2023 and will apply to fiscal years beginning from that date, except for the UTPR which will apply to fiscal years beginning 31 December 2024.
Read a December 2023 report prepared by the KPMG member firm in Belgium
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