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Belgium: Incorporation of Amount B guidance; technical documentation on GloBE information return

Incorporation of OECD Amount B guidance effective for fiscal years beginning on or after January 1, 2025

may 4, 2026

Circular 2026/C/45 (published on March 19, 2026) confirmed that Belgium generally adopts the OECD Pillar One Amount B guidance, as set out in the Inclusive Framework on BEPS report of February 19, 2024, as part of its local transfer pricing rules—effective for fiscal years beginning on or after January 1, 2025.

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

In addition, the tax authorities have published technical documentation on the global anti-base erosion (GloBE) information return (GIR).

The documentation mainly consists of OECD materials regarding the GIR and the exchange of information, but it also includes additional Belgian validation rules. However, the validation rules are still in draft form and remain subject to the transposition of DAC9 into Belgian law.

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

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