Belgium: Draft UTPR top-up tax return published for public consultation
Draft materials for assessment year 2025, with feedback accepted until July 3, 2026
The Belgian tax authorities published the draft undertaxed profits rule (UTPR) top-up tax return and accompanying explanatory notes for public consultation. Stakeholders can submit feedback until July 3, 2026.
The draft materials concern assessment year 2025. Under the Belgian Law on Minimum Taxation (Pillar Two), the UTPR top-up tax would become effective for fiscal years beginning from December 31, 2024. In Belgium, the UTPR top-up tax return is a formal tax return and would trigger the issuance of an assessment notice.
The filing deadline for the UTPR top-up tax return is, in principle, the last day of the 15th month following the end of the fiscal year, aligning with the information return (the Belgian equivalent of the GloBE information return (GIR) or top-up tax information return (TIR)). Therefore, when the fiscal year coincides with the calendar year, the first filing deadline is March 31, 2027.
As a general reminder, the first filing deadline of the information report (GIR or TIR) is June 30, 2026, while the GIR notification deadline was recently postponed to September 30, 2026.
Read a June 2026 report prepared by the KPMG member firm in Belgium