Belgium has published the official return form for its Pillar Two domestic minimum top-up tax (QDMTT), requiring multinational enterprises and large domestic groups to file detailed tax structure and income data beginning with the 2024 tax year. The gazetted Royal Decree formalises Belgium's adoption of the OECD global minimum tax rules. 

RF Report

Belgium has gazetted the Royal Decree of 25 May 2026, which officially approves the model form for the supplementary national tax return for the 2024 tax year.

The supplementary national tax represents Belgium’s qualified domestic minimum top-up tax (QDMTT), implemented in line with the Pillar Two global minimum tax rules under Council Directive (EU) 2022/2523 of 14 December 2022.

The Decree also includes the detailed multilingual tax form, which requires companies to provide data on their corporate structure, financial profits, and advance tax payments. It acts as a comprehensive legal registry detailing new fiscal obligations, regulatory changes, and institutional personnel updates in Belgium.

The key details regarding this tax and its return form include:

Legal basis and Pillar Two alignment

The decree was issued in implementation of the Law of 19 December 2023, which introduced a minimum tax for multinational enterprises and large-scale domestic groups in Belgium. The tax return form itself is explicitly labelled with the abbreviation “P2-DMTT” (Pillar Two – Domestic Minimum Top-up Tax) in its margins, confirming its role as Belgium’s qualified domestic minimum top-up tax (QDMTT).

Return deadlines and content

The approved form (included as an annex to the decree) applies to reporting years ending on 31 December 2023 or during 2024 before 31 December.

The standard deadline for submitting the QDMTT return is the last day of the eleventh month following the end of the fiscal year. For example, the return for the tax year ending 31 December 2024 would normally have been due by 30 November 2025.

However, the deadline has been extended. It was first extended to 30 June 2026 for fiscal years ending up to 30 June 2025, and subsequently further extended to 30 September 2026 for fiscal years ending up to 30 September 2025, as announced by Belgium’s Federal Public Service (SPF) in April 2026.

The return requires detailed information, including:

  • Identification of the taxpayer and the multinational or large-scale domestic group.
  • Corporate structure details, such as the ultimate parent entity and various Belgian group entities or joint ventures.
  • Specific elections regarding safe harbours and other Pillar 2-related jurisdictional or group entity choices.
  • Calculations of the net qualifying income, adjusted covered taxes, the effective tax rate, and the resulting supplementary national tax due in both the presentation currency and euros.
  • Details on advance tax payments made specifically for Pillar 2.

Effective date

The provisions regarding this supplementary national tax apply to reporting years beginning on or after 31 December 2023.