The tax authorities in Belgium have announced that the filing deadline for both the qualifying domestic minimum top-up tax and the top-up tax under the income inclusion rule (IIR) has been extended.
Qualifying Domestic Minimum Top-Up Tax
The filing deadline for reporting years that start on 31 December 2023 or later, and reporting years ending on 1 January 2024 at the earliest and 30 September 2025 at the latest, is extended from 17 November 2025 to 30 September 2026.
IIR Surcharge
The filing deadline for reporting years commencing at the earliest on 1 January 2025 and ending on 31 May 2025 at the latest is extended to 30 September 2026. The same extension applies for reporting years commencing from 31 December 2023 and ending on 31 December 2024 at the latest, and reporting years ending on 28 February 2025 at the latest.
Practical guidelines and technical documentation regarding the declaration procedure will be communicated later.
The full text of the announcement of 3 April 2026, is available here (in Dutch).
“Given the delay in Belgium, it will be interesting to see which countries follow their lead and provide additional time to comply with the multitude of Pillar 2 rules. Global businesses require certainty regarding what Pillar 2 compliance requirements exist where, specifically with details of how to comply in all the relevant countries.”
Find out more about BEPS 2.0
For more information on the BEPS tax framework or other corporate international tax matters, please contact us, or email Chris Denning or Chris Danes from our International Tax team, who will be happy to assist:
Chris Denning, Head of Corporate International Tax: chris.denning@mha.co.uk
Chris Danes, Tax Partner: chris.danes@mha.co.uk
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