Belgium: Proposal to introduce digital services tax
The bill proposes a 3% digital services tax on large multinational groups providing digital services in Belgium without a permanent establishment.
The Chamber of Representatives (lower house) on April 17, 2026, accepted for consideration Bill No. 56K1491001, which, if adopted, would introduce a 3% digital services tax (DST) for multinational enterprise (MNE) group entities providing digital services in Belgium, effective January 1, 2027.
Taxpayers in scope
The bill targets only large international digital groups and excludes small and medium-sized businesses. A group falls in scope when it records more than €750 million in worldwide consolidated revenue for the previous financial year (ending December 31) and more than €3 million in taxable digital revenue in Belgium in that same year.
Transactions in scope
The bill covers three categories of digital transactions that involve users located in Belgium:
- Targeted online advertising, when a business earns revenue by displaying digital advertisements to users in Belgium, usually selected based on user behavior, interests, or profiles
- Digital intermediation services, when a platform, website, or mobile app connects users with each other or with businesses—for example, online marketplaces, ride-hailing apps, or booking platforms—and at least one of the participants in the interaction uses the service from Belgium
- Monetization of user data, when a business transfers, grants access to, or otherwise earns revenue from data that users in Belgium generate, such as user profiles, usage patterns, browsing history, or other user-generated information
Sourcing rules
Revenues would be sourced to Belgium if the in-scope transactions relate to users located in Belgium. To identify a Belgian user, the bill states that taxpayers must use the IP address or any other objective geolocation criteria. When a digital activity simultaneously involves users in multiple countries and generates a single stream of revenue, the government will issue allocation rules that require businesses to split that revenue across countries using a reasonable method.
Tax base
The tax base would consist of the gross revenue that an in-scope group earns from the covered digital transactions when those transactions relate to users in Belgium:
- For online advertising, the total amounts advertisers pay for ads displayed to Belgian users
- For digital intermediation services, the total value of transactions facilitated between users, at least one of whom is Belgian
- For monetization of user data, the total value of transfers or commercial uses of data belonging to Belgian users
Exclusions
The bill does not include specific carve-outs for particular industries.
Compliance obligations
In-scope groups would be required to file a tax return and pay the DST to the Belgian federal tax administration by the last day of the third month following the end of its financial year. The government would be required to issue detailed rules specifying the format and content of the return, the method for filing, and the procedures for payment, including bank details and reference requirements.
If a group does not maintain a permanent establishment in Belgium, it would be required to appoint a tax representative established in Belgium.
The bill aligns penalties, interest, and enforcement mechanisms with those in the Belgian income tax code. As a result, late filing, late payment, underreporting of taxable revenue, or failure to meet procedural obligations can trigger administrative fines, late-payment interest, and other corrective measures.
The legislation would take effect on January 1, 2027, and the government must issue implementing regulations within three months after that date to provide the practical and technical details needed for businesses to comply.
KPMG observation
While this proposal was submitted by members of a minority party in the Belgian parliament, it shows that interest in DSTs and similar measures has not diminished. Indeed, the Belgian proposal follows a similar proposal recently introduced in Poland as well as the adoption of a significant economic presence standard in Cameroon and Côte d’Ivoire. Businesses involved in the digital economy may need to continue to monitor this space carefully so that they remain compliant with all foreign tax obligations.
For more information, contact a KPMG tax professional:
Philippe Stephanny | philippestephanny@kpmg.com
Chinedu Nwachukwu | chinedunwachukwu@kpmg.com