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
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
US House Advances the ‘One, Big, Beautiful Bill’ Bill to the Senate – This could have significant implications for Belgian and other non-US Companies with US presence and investment
On 22 May 2025, the US House of Representatives approved the “One, Big, Beautiful Bill” (OBBB). The Bill is now set for Senate deliberations which are expected to follow swiftly. The Republican majority aims to have the bill signed into law by President Trump before the July 4th recess. The legislation features permanent extensions and
DAC 9 – The EU Council agrees to enhance cooperation and information exchange on minimum effective corporate taxation
On Tuesday 11 March 2025 the EU Council reached a political agreement on the Directive on Administrative Cooperation in the field of taxation, also referred to as DAC9. What is DAC9? DAC9 updates the existing EU’s Directive on Administrative Cooperation (DAC) by expanding tax transparency rules. In particular, the update aims to simplify reporting for
The OECD released a new package of Pillar 2 documents
On 15 January 2025, the OECD released a new package of documents including (i) the central record of legislation with qualified domestic rules, (ii) additional Administrative Guidance, and (iii) an updated version of the GloBE Information Return (GIR), the XML scheme/user guide and a Multilateral Competent Authority Agreement. List of legislations with a Transitional Qualified
Circular letter on the Belgian CFC rules (Circular Letter 2024/C/82 December 13, 2024)
On 13 December 2024, the Belgian tax authorities issued a circular letter (Circular Letter 2024/C/82 December 13, 2024) regarding the new Belgian Controlled Foreign Corporation (CFC) regulations and a circular letter (Circular Letter 2024/C/83 December 13, 2024) regarding changes from a tax procedural perspective. Almost one year ago, the program law of 22 December 2023
OECD issues a fourth package of Administrative Guidance on Global Anti-Base Erosion Model Rules (Pillar 2)
On 17 June 2024, the OECD released the fourth set of Administrative Guidance on GloBE rules, with the intention of clarifying the operation of these rules. This package follows the Administrative Guidance sets released in February, July and December last year. It is the first package of Administrative Guidance following the publication of the Consolidated
Belgian law amending the investment deduction and innovation income deduction regime published in the Official Gazette
On 29 May 2024, the law of 12 May 2024 containing various tax provisions was published in the Belgian Official Gazette. This law implements several changes to the regime of the investment deduction and the innovation income deduction (IID). Key features of the new legislation are summarized below. For more information, we refer to our
