Belgium agrees on core principles for implementation of the Global Minimum Tax (GloBE/Pillar 2) for MNE’s and some additional tax measures


The Belgian government reached an agreement on the Federal budget. After long discussions within the government, a number of measures have been decided that will reduce expenditures and measures that will increase revenue. 

One of the key elements in the budget decision was the decision on the core principles of the introduction of Pillar 2 in Belgium:

  • In the budget agreement, it has amongst others been decided that Belgium will introduce a domestic top up tax (QDMTT) and will include the Pillar 2 in the existing tax prepayment schedule. As a result of this, companies in scope of Pillar 2 will be required to consider advance tax payments for Pillar 2.
  • In addition, the tax liability will be established on behalf of one group entity, with the other group entities being jointly and severally liable for the tax liability.
  • The Belgian tax credit for Research and Development would be adapted in order to align with the requirements of Pillar 2 (meaning that the repayment period would be reduced from 5 to 4 years).

In addition to the foregoing, also some other tax measures are taken:

  • Adaptation of the so-called ‘Patrimonium tax’ from a flat rate system to a progressive rate system, which applies to non-profit associations (health sector non-profit associations would be excluded). 
  • Increase of the number of tax inspectors to focus on specific areas such as VAT and professional withholding tax.
  • Mandatory reporting on professional rental payments.
  • New increase of the excises on tobacco and on new tobacco products from 2024.
  • Regional tax on gambling and betting and the tax on amusement machines would be no longer deductible.

These measures will now be translated into a proposal of law and go through the legislative process, and be adopted by the Chamber before coming into effect. 

It should be noted that, along the budget discussions, the government is also looking at a tax shift / tax reform. At this point in time, there is no final agreement yet on the tax reform proposal issued by the Belgian Ministry of Finance some weeks ago.

For more insights on the impact of these possible changes, please do not hesitate to reach out to your regular PwC contact, or contact Pieter Deré