Belgium: Guidance on implementation of Pillar Two rules
Consistent with previously provided EU and OECD guidance
The Belgian Tax Authorities issued Circular 2025/C/68 providing guidance on implementation of the Pillar Two rules in Belgium.
The circular provides guidance in line with guidance previously provided by the EU and OECD on:
- Criteria for determining the entities subject to the rules
- Calculation methods for the top-up taxes
- General compliance requirements
KPMG observation
While the circular is quite extensive, it does not really include new insights on the Pillar Two rules beyond the existing EU and OECD guidance.
Read an October 2025 report prepared by the KPMG member firm in Belgium