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Belgium: Draft legislation amending Pillar Two rules

Key procedural updates on DMTT, assessment rules, and compliance obligations

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October 10, 2025

A draft law amending the Belgian Pillar Two rules was submitted to Parliament. The proposed changes, which could affect the first deadline for domestic minimum top-up tax (DMTT) compliance in November 2025, relate to: 

  • Electronic platform
  • Definition of “group”
  • Definition of “filing constituent entity”
  • DMTT liability
  • Codification of the assessment system
  • General representative
  • Statute of limitations
  • Joint & several liability
KPMG observation
The Belgian DMTT is qualified based on the OECD’s central record (i.e., QDMTT). However, the deadline for submitting the QDMTT return is much earlier than in other countries (i.e., 11 months following the fiscal year). While this deadline is quickly approaching, the tax administration has not yet provided details and instruction concerning the technicalities of the filing. More information is expected shortly. 

Read an October 2025 report prepared by the KPMG member firm in Belgium

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