Belgium: Obligation to pay top-up tax under UTPR on low-taxed profits of group members outside Belgium (CJEU referral)

Referral by Belgian Constitutional Court of question related to UTPR

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July 18, 2025

The Belgian Constitutional Court on July 17, 2025, referred to the Court of Justice of the European Union (CJEU) the question of whether the obligation of Belgian members of a multinational enterprise (MNE) group to pay a top-up tax under the undertaxed profits rule (UTPR) on low-taxed profits of group members located outside Belgium—without considering the financial position of the Belgian constituent entity—violates EU law.

Read a July 2025 report prepared by the KPMG member firm in Belgium

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