Belgium has released comprehensive administrative guidance on the 2023 law introducing a minimum tax for large multinational and domestic groups, aligning with OECD/G20 BEPS 2.0 Pillar Two rules and detailing definitions, calculation methods, transitional measures, and supplementary tax provisions.
Belgium’s Federal Public Service (SPF) Finance has published the Circular 2025/C/68 on 23 October 2025 in regards to the introduction of a minimum tax for multinational enterprise groups and large national groups, which was introduced under the Law of 19 December 2023.
The Circular issued by Belgium’s Federal Public Service Finance (SPF Finance) on 22 October 2025 provides detailed administrative guidance on the law of 19 December 2023, which introduces a minimum tax for multinational enterprise groups and large national groups.
It aligns Belgium’s tax framework with the OECD/G20 BEPS 2.0 Pillar Two rules and the related EU Directive, setting a minimum effective tax rate for large companies with consolidated annual revenues of at least EUR 750 million.
This Circular also provides an explanation for complex definitions for terms such as “constituent entity,” “group,” and “excluded entities.” The document thoroughly explains the calculation of the effective tax rate (ETR) and the resultant additional tax (top-up tax), including rules for determining allowable profit or loss, handling deferred taxes, and allocating taxes among group entities.
Furthermore, it covers specialised topics like transitional safe harbour regimes based on Country-by-Country (CbCR) reports, rules for reorganisations and mergers, and the application of a National Supplementary Tax.
