On 14 December 2023, the Belgian parliament approved the draft bill to implement the global minimum tax, Pillar 2, into Belgian law. On 30 November 2023, the draft law for implementing the global minimum tax Pillar Two was accepted by the Belgian Parliament as per the EU directive 2022/2523 of 14 December 2022.
The law includes the incorporation of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to establish a minimum tax rate of 15% for multinational enterprise (MNE) groups that have an annual consolidated revenue of at least EUR 750 million in a minimum of two out of the previous four fiscal years. The law also includes the introduction of a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups, as well as permanent and transitional safe harbor rules.
The proposed legislation is anticipated to be approved by year-end, and its provisions will take effect on 1 January 2024 for taxpayers.
