Latest news & developments
2026 Budget agreement – Tax and social measures
Today, the government reached a budget agreement, setting a multi-year path to meet the European expenditure rule by 2029. This plan involves 60% spending cuts and 40% new revenue streams. A projected €9.2 billion is earmarked for 2029, increasing to €10 billion by 2030. This funding will come from salary indexation adjustments, targeted VAT hikes,
Belgium extends the filing deadline of the QDMTT return to 30 June 2026
What happened? Today, Belgium announced an extension of the deadline to file the Qualified Domestic Minimum Top-up Tax (“QDMTT”) return to 30 June 2026 for taxpayers with a financial year which: started at the earliest on 31 December 2023, and ended at the earliest on 1 January 2024 and at the latest on 30 June 2025. In its communication (available in Dutch and in French), the Belgian Ministry of Finance explains that this means
Simplified side stream mergers – new law clears hurdles for ‘real’ tax neutrality
On 16 June 2023, the ‘simplified side stream merger’ (vereenvoudigde zusterfusie / fusion simplifiée entre soeurs) was introduced in the Code of Companies and Associations and in the Income Tax Code. However, even in case all conditions were fulfilled, the transaction could not entirely take place tax neutrally due to ‘imperfections’ in the corporate income
Significant update for family businesses in Flanders
On 3 October 2025, the Flemish Government gave preliminary approval to a draft decree that will bring substantial changes to the preferential tax regime for family businesses, particularly affecting those with residential real estate assets. These reforms are set to take effect on 1 January 2026 and will exclude residential real estate and building land
Ministry of Finance publishes Pillar 2 Circular Letter
On 22 October 2025, Belgium’s Federal Public Service Finance issued the Circular Letter 2025/C/68 providing extensive administrative guidance on the Belgian minimum tax regime for multinational enterprise (MNE) groups and large domestic groups (“the Pillar 2 Circular Letter”). The document has approximately 400 pages and is available in Dutch and French. It provides administrative guidance with
The structural risk of circular transactions
When the accurate delineation of a cash pool balance shows that the same short-term lending or depositing position remains present year after year, the OECD Guidelines detail it may be appropriate to treat such a financing position as something else, such as a long-term loan. In line with this OECD guidance, multinational groups often undertake
Belgian draft law amending the Pillar 2 Law
On 9 October 2025, the Belgian government submitted to Parliament a draft law introducing technical amendments to the law of 19 December 2023 (the “Pillar 2 Law”), which implemented a minimum tax for multinational enterprises (MNEs) and large domestic groups. Please also refer to our previous news alert. What is included in the draft
Key insights and practical challenges as we enter the third year of DAC 7 compliance in Belgium
As Belgium enters the third year of DAC7 reporting, the regime is now well established. For many businesses, DAC7 has become a recurring compliance obligation, yet its complexity and the ongoing increase of non-EU countries adopting similar regimes continue to create new challenges. This newsflash offers a concise recap of DAC7 and highlights key focus
