Belgium’s Finance Minister has submitted a draft bill to Parliament establishing the legal and operational framework for DAC9, including automatic exchange of Pillar Two Information Reports, new penalties for non-compliance, and retroactive application from 1 January 2026.
Belgium’s Minister of Finance submitted a draft bill (Doc 56 1719/001) to the parliament on 10 September 2026 that establishes the operational and statutory framework for implementing Council Directive (EU) 2025/872 (DAC9) into Belgian domestic tax law. This directive amends Directive 2011/16/EU on administrative cooperation in the field of taxation.
The draft bill’s primary purpose is to establish the automatic exchange of information on the Pillar Two Information Report. This operationalises the reporting obligations introduced by EU Minimum Taxation Directive 2022/2523 and the Belgian Pillar Two Law of 19 December 2023, ensuring global minimum tax compliance across international group entities.
Integration with domestic rules & third-country frameworks
Belgium’s Pillar Two law uses the existing automatic exchange framework under Article 338 of the Belgian Income Tax Code 1992 instead of creating separate procedures. For exchanges with non-EU countries, Belgium will use the OECD/G20 Inclusive Framework’s Multilateral Competent Authority Agreement on the Exchange of GloBE Information. Belgium is currently ratifying the agreement.
Filing requirements & correction deadlines
The DAC9 Information Report can be submitted centrally by the Ultimate Parent Entity (UPE) or a Designated Filing Entity established in Belgium or another EU Member State with an active qualifying agreement. When filed centrally, local Belgian constituent entities are exempt from filing duplicate reports under Article 53 (though notification rules apply).
If the Belgian tax authority issues a formal correction request (following internal audit or notification from another Member State), the reporting entity established in Belgium must submit a corrected information report within one month from receiving the request.
A correction request is legally presumed to be received on the 3rd business day following its mailing under a closed envelope or its electronic upload to the SPF Finances platform
Penalties and sanctions regime (Article 61 of the Pillar Two Law)
The draft bill proposes new penalties for Pillar Two violations.
Failing to file, filing late, or failing to pay top-up tax could result in fines of EUR 2,500 to EUR 125,000, rising to EUR 250,000 in cases involving fraud or intent to cause harm. Incorrect or incomplete filings could attract fines of EUR 1,250 to EUR 62,500, or up to EUR 125,000 where fraud or intent to cause harm is involved.
The tax administration may waive penalties where there is no bad faith. Judges may also reduce fines for mitigating circumstances, but not below 40% of the applicable minimum.
The King would be authorised to set graduated penalty scales based on the seriousness and repetition of violations.
Implementation timeline, technical adjustments & entry into force
Belgium will make its first automatic DAC9 information exchange no earlier than 1 December 2026. The bill also makes technical changes to the Pillar Two Law to correct references, align filing deadlines, and clearly separate local tax declarations from the global DAC9 report.
The bill will take effect when it is published in the Belgian Official Gazette, but will apply retroactively from 1 January 2026.
Earlier, Belgium’s government announced on 22 May 2026 that the Council of Ministers approved a preliminary draft law to transpose the DAC9 Directive into Belgian law and amend the legislation implementing the minimum tax for multinational and large domestic groups.
