Belgium has issued a draft schema outlining how groups should file their Pillar 2 top-up tax return under the new QDMTT rules.

Belgium’s tax authorities, Federal Public Service (FPS) Finance has issued a draft XSD schema for the annual supplementary national tax return on 10 April 2025.

This release follows the publication of the draft return form in April 2025. The supplementary national tax represents Belgium’s implementation of the qualified domestic minimum top-up tax (QDMTT) under the Pillar Two global minimum tax framework.

The QDMTT was introduced in line with Council Directive (EU) 2022/2523 of 14 December 2022 and applies to in-scope groups for tax years starting on or after 31 December 2023.

Updated draft mandates inclusion of the following:

  • Information on the Belgian designated filing entity and the group’s reporting year. Information on the paying constituent entity has been removed in this draft.
  • Reporting must include the ultimate parent entity, Belgian group entities (constituent and joint ventures), and excluded entities. If no changes occurred from the prior year, a confirmation checkbox may be used.
  • Belgian subgroups must report whether they qualify under safe harbour rules or de minimis exclusions. Filing is still required even if these apply. Further guidance is expected.
  • Any elections made by Belgian subgroups—such as for stock-based compensation expense—must be disclosed.
  • Required data includes the Financial Accounting Net Income or Loss, net GloBE Income (Loss), accrued taxes, Adjusted Covered Taxes, and tax reallocations. No significant changes from the previous draft were noted.
  • The draft includes provisions for reporting Pillar Two prepayments and any excess corporate income tax prepayments that may be credited. QDMTT-specific prepayments generate a 12% credit, while excess corporate tax prepayments generate tiered credits (12%, 10%, 8%, or 6%) based on the payment quarter. These credits are capped at the 9% QDMTT surcharge.
  • The return must include the full contact details of an appointed representative and be signed by a person legally authorised to represent the filing entity. The signature requirement is a new addition.

Earlier, the Federal Public Service (SPF) Finance of Belgium released its guidance on the Pillar Two global minimum tax, outlining its context and enforcement in Belgium.