The Belgian tax authorities have extended the deadline for multinational enterprises and large domestic groups to designate their global minimum tax information return (GIR) filer.
Belgium’s tax authorities announced, on 12 June 2026, that it has postponed the deadline for multinational enterprises and large domestic groups to identify which entity will submit the global minimum tax information return (GIR).
The notification portal will launch on 1 July 2026, with submissions required by 30 September 2026 for the 2024 and 2025 assessment years.
New filing portal opens mid-2026
Under the Law of 19 December 2023, which introduced minimum tax requirements for in-scope groups, taxpayers must designate a single entity to file the GIR on behalf of the entire group (Articles 53(3) and 54(2)). The tax authority will publish detailed submission procedures once the portal becomes operational.
Key dates and requirements
Groups have until 30 September 2026 to notify their designated GIR filing entity for both 2024 and 2025.
This extended timeline provides additional time for multinational enterprises and large domestic groups to ensure compliance with the global minimum tax framework before submission commences.
Law of 19 December 2023, or the Belgian Pillar Two Global Minimum Tax Act, enacted on 19 December 2023, establishes a minimum tax rate for multinational enterprises (MNEs) and large-scale domestic groups. This law transposes EU Directive (EU) 2022/2523, which aims to ensure a global minimum tax rate of 15%. The legislation applies to group entities established in Belgium that are part of a group with annual revenues of at least EUR 750 million.
To ensure tax compliance, the law introduces three distinct mechanisms: a domestic top-up tax, an Income Inclusion Rule (IIR), and an Undertaxed Profit Rule (UTPR). Detailed definitions are provided for various organisational structures, including pension funds, non-profit organisations, and investment entities, many of which are specifically excluded from the scope of the tax.
Additionally, the text specifies rigorous accounting standards and adjustment methods required to calculate qualifying income and adjusted covered taxes. Ultimately, these measures aim to prevent base erosion and ensure that large entities contribute a fair share of tax across all jurisdictions where they operate.
