On 1 June 2026, a Royal Decree has been published in the Belgian Official Gazette establishing the official template for the Qualified Domestic Minimum Top-Up Tax (QDMTT) return for assessment year 2024. The published return is applicable for fiscal years that started on or after 31 December 2023 but ended on 30 December 2024 at the latest. Note that the Belgian Pillar 2 law is applicable for fiscal years that started on or after 31 December 2023.
The official QDMTT return template released for assessment year 2024 is aligned with the latest draft version released by the Belgian tax authorities in March 2026.
Below you’ll find a recap on our key takeaways further to the publication of this Royal Decree, as well as an overview of the content of the template released today.
Key Takeaways
- The Belgian QDMTT return must in principle be filed within 11 months after the end of the fiscal year. When the legal deadline falls before 30 September 2026, an exceptional general extension was granted until 30 September 2026. We refer to our newsflash in this respect.
- The Royal Decree released only covers the QDMTT return template related to the assessment year 2024. We expect the QDMTT return related to the assessment year 2025 (related to fiscal years that ended 31 December 2024 or in 2025 but before 31 December) to be released shortly, considering that no major differences are expected between the forms.
- As a reminder, the fiscal year refers to the accounting period for which the ultimate parent entity of an MNE group or a large-scale domestic group prepares its consolidated financial statements, or, where the ultimate parent entity does not do so, the period corresponding to the calendar year.
- The Belgian Pillar 2 identification number is a mandatory field in the Belgian QDMTT return. Therefore, the Pillar 2 notification must have been successfully filed and the group number received prior to the filing of the return. Please also refer to our newsflash in this respect.
- When a MNE group falls in scope of the Belgian Pillar 2 law, a Belgian QDMTT return is expected to be submitted, regardless of whether a Pillar 2 safe harbour applies to Belgium.
- It is expected that the form should be filed in an XML format through the Biztax mandate on the MyMinfin e-platform of the Belgian designated filing entity. Note that the filing platform is not open yet and no final filing guidance is available per today, but the MyMinfin accesses can already be arranged.
- Although the Belgian forms of the GloBE Information Return (“GIR”) and GIR Notification are not yet available, the deadline of 18 months after the end of the first reporting year is still applicable. For calendar year MNE groups, the first GIR (Notification) is still due by 30 June 2026.
Content of the QDMTT Return
The return form related for assessment year 2024 contains eight main sections covering the full scope of information required from in-scope groups:
1. Identification – identification of the taxpayer(s) subject to the Belgian QDMTT, the filing entity established in Belgium, and information on the MNE group or large-scale domestic group (including the Belgian Pillar 2 identification number, fiscal year dates, and presentation currency).
2. Group Structure – information about the ultimate parent entity, Belgian group entities (both constituent entities and joint ventures (affiliates)) and Belgian excluded entities must be reported. Information on the direct parent entity of the Belgian group entities must also be reported.
3. 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.
4. Elections – the elections made per Belgian subgroup (e.g. stock-based compensation expense or simplified calculations for non-material entities) should be identified.
5. Calculation of the QDMTT – computation of the domestic top-up tax rate and the actual QDMTT, including Financial Accounting Net Income or Loss, the net GloBE Income (Loss), tax accrued in the financial accounts, Adjusted Covered Taxes and substance-based income exclusion.
6. 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.
7. Determination of the Belgian QDMTT due – per Belgian subgroup, final determination of the QDMTT due (including the surcharge for absence or insufficiency of advance payments), total advance payments, and the net amount still due or to be refunded.
8. Contact Person — designation of a contact person by the Belgian filing entity.
How can we assist you?
As the deadlines for the submission of the Belgian Pillar 2 compliance requirements (i.e. GIR (notification) and Belgian QDMTT return) are around the corner, action is required to ensure timely filing.
Are you looking for support to comply with Pillar 2 in Belgium or abroad? Why not reach out to your regular PwC contact, or contact 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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