On 10 April 2025, the Belgian tax authorities published a new version of the draft Belgian Qualified Domestic Minimum Top-up Tax return (also referred to as QDMTT return) to be submitted by Belgian entities subject to the Belgian law introducing a global minimum tax (or Pillar 2).
This new version is an update of the first QDMTT return published on 18 October 2024. Although the version published on 10 April 2025 is expected to be close to final, it remains provisional until formal publication in the Belgian Official Gazette.
As a reminder, the Belgian QDMTT return should be filed, regardless of whether the transitional CbCR Safe Harbours are met, on an annual basis within 11 months after the last day of the reporting year in scope. For in-scope groups with a financial year aligned with the calendar year, this means the first due date to file the return will be 30 November 2025.
What’s new?
While the information requested in this new draft, applicable to assessment year 2025 (financial years ended between 31 December 2024 and on or before 30 December 2025), is overall slightly lighter, it does not include any major adjustments compared to the first version. Below is an overview of the information to be reported based on the latest draft return:
- Identification – information on the Belgian designated filing entity and the large (domestic/MNE) group and its reporting year is requested. Information related to the paying constituent entity is no longer to be included based on the latest draft QDMTT return.
- Group structure – information about the ultimate parent entity, Belgian group entities (both constituent entities and joint ventures (affiliates)) and excluded entities must be reported. Note that, as per the latest draft, in case no changes are to be reported on the information of the Belgian group entities (and their shareholding) and/or the excluded entities compared to the prior year, a specific box can be completed accordingly.
- Safe Harbours – per Belgian subgroup, information regarding the safe harbours and de-minimis exclusion are to be reported. Even though the safe harbours are applicable, a Belgian QDMTT return will need to be submitted. However, additional clarification from the Belgian tax authorities is still expected on the sections to be completed in case a Belgian subgroup falls under a safe harbour.
- Elections – the elections made per Belgian subgroup (e.g. stock-based compensation expense) should be identified. No major changes were noted in the latest draft.
- Calculation of the Belgian QDMTT – limited number of data points per Belgian subgroup including the Financial Accounting Net Income or Loss, the net GloBE Income (Loss), Tax accrued in the financial accounts, Adjusted Covered Taxes and taxes to be reallocated under the QDMTT rules. No major changes were noted in the latest draft.
- Prepayments – information regarding the prepayments made in the context of Pillar 2 and excess prepayments for corporate income tax purposes (that may be used for Pillar 2). Please also refer to our newsflash in this respect.
- Calculation of any Belgian QDMTT due – per Belgian subgroup, the form includes a calculation sheet to arrive at the additional Belgian QDMTT due, taking into account the prepayments made (if any). Compared to the previous draft, the latest version of the QDMTT return suggests that the amount of Belgian QDMTT due by Belgian subgroup is expected to be completed in Euro.
This section also suggests that the prepayments made for Belgian QDMTT purposes in relation to assessment year 2025 lead to a credit of 12% regardless of when the payments were made. On the contrary, the prepayments made in excess for corporate income tax purposes lead to a credit of 12%, 10%, 8% or 6% depending on the quarter during which these payments were made. Note that the credits are to be offset against (but limited to) the surcharge of 9% of the Belgian QDMTT due.
- Contact person – the full contact details of a person appointed by the (designated) filing entity must be provided. This section includes information previously reported in the first section of the draft QDMTT return as published in October 2024.
- Signature – the Belgian QDMTT return must be signed by (a) person(s) who can legally bind or represent the (designated) filing entity. This section is new.
What’s next?
The Belgian tax authorities noted on their website that the final Belgian QDMTT return as well as further administrative guidance on the return will be published at a later stage. The additional guidance is intended to provide clarification on the data points to be reported in the Belgian QDMTT return as well as further information on the actual filing of the QDMTT return. The XSD scheme is also expected to be released as soon as possible.
How can we assist you?
As the deadline for the Belgian QDMTT return will be fast approaching and is also very close to the deadline for filing Belgian corporate income tax returns, immediate action is required to ensure that all data points are readily available, initiate data collection and assess whether the transitional CbCR safe harbours can be claimed for Belgium.
We would also be happy to assist with the computation and optimisation of the advance tax payments to be made for assessment year 2026 in relation to Belgian QDMTT and/or IIR (also considering advance tax payments for Belgian corporate income tax) and define your Pillar 2 compliance game plan.
Reach out to your regular contact person or Pieter Deré (pieter.dere@pwc.com), Koen De Grave (koen.de.grave@pwc.com) or Maxim Allart (maxim.allart@pwc.com).
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