Belgium's Federal Public Service Finance has opened a public consultation, running until 3 July 2026, on a draft UTPR top-up tax return form and explanatory guidance for the 2025 assessment year, covering electronic filing, representative agent requirements, and safe harbour reporting under Pillar Two.
Belgium has launched a public consultation on a draft undertaxed payments rule (UTPR) top-up tax form and related explanatory guidance for the 2025 tax year.
UTPR explanatory guidance
Issued by the Federal Public Service Finance, the official guidance and instructions for filing the 2025 assessment year tax return related to the UTPR top-up tax in Belgium outline the mandatory electronic filing process via the MyMinFin platform for multinational groups.
It details the necessity of appointing a representative agent when multiple entities are involved and clarifies the interaction between this return and the GIR information report. The guidelines offer a section-by-section breakdown for identifying taxpayers, including specific procedures for permanent establishments and companies undergoing mergers or liquidations.
Additionally, it establishes technical definitions, lists relevant legal abbreviations, and explains how to calculate tax liabilities using official exchange rates.
UTPR top-up tax form
The official Belgian tax declaration form has been specifically designed for the UTPR top-up tax for the 2025 assessment year. It requires multinational groups to provide detailed identification data, including fiscal registration numbers and information regarding their consolidated financial statements.
The form facilitates the calculation of additional tax liabilities in accordance with Pillar Two global minimum tax regulations, requiring figures in both the reporting currency and euros. It includes dedicated sections for documenting safe harbour applications, subgroup performance, and the designation of a contact person within Belgium.
Finally, the paperwork must be formally validated and signed by an authorised representative to certify the accuracy of the reported financial information.
The consultation runs from 16 June to 3 July 2026, and comments may be submitted to the Ministry of Finance via email at pillar2@minfin.fed.be.
