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Belgium: Guidance on currency conversion for global minimum tax

Based on OECD consolidated commentary published in May 2025

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March 18, 2026

The tax authorities issued Circular 2026/C/41, as an addendum to Circular 2025/C/68 on the introduction of a minimum tax for multinational enterprises and large domestic groups, to provide guidance on currency conversion for global minimum tax purposes.

The guidance, which is based on the OECD consolidated commentary published in May 2025, clarifies the rules for converting amounts into euros when they are reported in another currency in the consolidated financial statements and when the top-up tax is calculated in a currency other than the euro. Compared with the OECD rules, the most important clarification is that, for Belgium, the top‑up tax in the presentation currency must be converted using the exchange rate on the last day of the fiscal year, based on the European Central Bank (ECB) reference rate.

Read a March 2026 report prepared by the KPMG member firm in Belgium

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