Belgium has enacted legislation implementing DAC9, establishing requirements for top-up tax information reporting and the automatic exchange of GloBE Information Returns (GIRs) between EU Member States, with the first exchanges scheduled no earlier than 1 December 2026.
Belgium has enacted legislation implementing the DAC9 rules on top-up tax reporting and the automatic exchange of information across borders. The law, dated 25 October 2026, was published in Official Gazette No. 249 on 30 October 2026.
This follows the Belgian Chamber of Representatives’ approval of 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 Top-up Tax Information Returns (GIRs) and supports the filing requirements under the EU Pillar Two Global Minimum Tax Directive (EU) 2022/2523.
The law introduces definitions for top-up tax information returns, which contain IIR or UTPR information, and their structure, comprising a General Section and Jurisdiction-Specific Sections. It also defines implementing Member States as those applying a qualified IIR, UTPR, or both, and QDMTT-only Member States as those applying only a Qualified Domestic Minimum Top-up Tax.
Information reporting & automatic exchange framework
Belgian filing entities must submit GIRs through the FPS Finance electronic platform, which identifies the required sections and recipient Member States. The Belgian competent authority must exchange returns within three months of the filing deadline or actual receipt of late filings. The first exchanges will take place no earlier than 1 December 2026. The law also requires amended returns within one month of a correction request.
