Belgium: Guidance on implementation of Pillar Two rules

Consistent with previously provided EU and OECD guidance

Share
October 24, 2025

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

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline