The Belgian Chamber of Representatives has approved legislation implementing DAC9, establishing rules for the automatic exchange of GloBE Information Returns, filing deadlines, and penalties for non-compliance under the EU Pillar Two global minimum tax framework.

The Belgian Chamber of Representatives approved a law implementing Council Directive (EU) 2025/872 of 14 April 2025 (DAC9) on 22 October 2026.

The directive establishes rules for the automatic exchange of information on Top-up Tax Information Returns, also known as GloBE Information Returns (GIR), and provides a framework for implementing the filing obligations under the EU Pillar Two Global Minimum Tax (GMT) Directive (EU) 2022/2523.

The draft law inserts several definitions into Article 3 of the Law of 19 December 2023:

  • Top-up tax information return: The return containing Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) top-up tax information, filed by an Ultimate Parent Entity (UPE), designated filing entity, designated local entity, or constituent entity.
  • Structure of the information return: Divided into a General Section (group-wide structure and high-level summary) and Jurisdiction-Specific Sections (detailed application of IIR, UTPR, and Qualified Domestic Minimum Top-up Tax / QDMTT for each jurisdiction where the group operates).
  • Implementing member states: Member States that have implemented a qualified IIR, a qualified UTPR, or both.
  • QDMTT-only member states: Member States that only apply a Qualified Domestic Minimum Top-up Tax.

Information reporting & automatic exchange framework

The law requires Belgian filing entities to submit GIRs through the FPS Finance electronic platform, which determines the relevant sections and recipient EU Member States. The Belgian

competent authority must exchange the returns within three months of the filing deadline or actual receipt if filed late, with the first exchanges scheduled no earlier than 1 December 2026. It also establishes procedures for correcting errors, requiring amended returns within one month of a correction request.

Fines & penalties

The bill establishes a standalone administrative penalty regime, replacing the general tax penalties under Article 445 of the Income Tax Code 1992.

Fines range from EUR 1,250 to EUR 125,000 for incomplete or inaccurate returns and from EUR 2,500 to EUR 125,000 for failure to file, late filing, or failure to pay allocated top-up tax. These penalties may increase to EUR 250,000 in cases involving fraudulent intent.

Fines may be waived where there is no bad faith, while mitigating circumstances may allow a judge to reduce the penalty to 40% of the applicable minimum.

Filing deadlines for tax returns

The law updates Article 52 of the Law of 19 December 2023, setting the tax return filing deadline at the last day of the 15th month after the reporting fiscal year ends. For fiscal years starting on or before 31 December 2024, a transitional deadline of the last day of the 18th month applies.

Data retention & enforcement

The law requires the Belgian competent authority to retain exchanged information for seven years from receipt, or longer if necessary to resolve ongoing disputes. It also updates financial account self-certification requirements under the Common Reporting Standard (CRS) and takes effect upon publication in the Belgian Official Gazette.

The draft bill will next be submitted to the King for signature before becoming law.

Earlier, Belgium’s Parliament’s Financial and Budgetary Committee adopted the draft legislation implementing DAC9 (Directive 2011/16/EU as amended by Council Directive (EU) 2025/872) on 2 October 2026.