The consultation follows December 2025 amendments implementing the EU Minimum Taxation Directive, requiring Belgian constituent entities to file supplementary tax declarations aligned with Globe Information Return (GIR) standards.
Belgium’s Federal Public Service (SPF) Finance has launched a public consultation on 17 March 2026 on draft top-up tax returns under the Pillar Two Income Inclusion Rule (IIR) for the 2024 and 2025 tax years, along with accompanying explanatory notes.
It also provides technical instructions for multinational enterprises and large-scale domestic groups on how to fulfil their Pillar Two electronic filing requirements via the MyMinFin platform.
Interested parties can participate by reviewing the draft declaration forms for the supplementary tax return under the Income Tax Reform Act for tax years 2024 and 2025, along with the corresponding draft explanatory notes related to the supplementary tax return under the RIR for both years.
Stakeholders may submit comments until 3 April 2026.
Belgian Pillar Two tax declaration requirements
Filing obligations
Every taxpayer subject to Belgium’s supplementary tax under the RIR must submit a declaration. This applies to all constituent entities established in Belgium under Article 31, § 1 of the Law of 19 December 2023. However, Belgian permanent establishments are exempt as they don’t qualify as parent entities. Groups with multiple Belgian entities must submit individual declarations for each.
Declaration structure
The filing aligns with Globe Information Return (GIR) codes and contains several key sections:
- Identification details: Taxpayers provide their Belgian Business Number (BCE/KBO), legal name, and banking information (IBAN/BIC). Groups must include their Pillar Two identification number and currency conversion rates using European Central Bank decimals if operating outside the Euro.
- Tax calculations: Section 2.1 covers the entity’s own Belgian supplementary tax, while Section 2.2 addresses taxes on other constituent entities or joint ventures. Various protection regimes are available, including QDMTT protection and temporary Country-by-Country reporting safe harbours.
Advance payments: Taxpayers report group-level Pillar Two advance payments allocated to them, with calculations determining any increases from insufficient payments.
Restrictions for 2024–2025
Permanent protection regimes (GIR1207, GIR1208, and GIR1209) covering de minimis rules, effective tax rate tests, and substance tests cannot be applied during 2024 and 2025. Additional documentation must be attached as PDFs labelled “Autres” in the electronic system, following guidance from Circular 2025/C/68.
Earlier, Belgium’s parliament passed amendments to the minimum tax law to implement the EU Minimum Taxation Directive (Directive (EU) 2022/2523), with approval on 18 December 2025 and publication in the Official Gazette on 30 December 2025.
