On Friday 18 October 2024, the Belgian tax authorities published the first version of the draft Belgian (Qualified) Domestic Minimum Top-up Tax return (also referred to as QDMTT return or QDMTT form) to be submitted by Belgian entities subject to the Belgian law introducing a global minimum tax (or Pillar 2).
What is Pillar 2?
Pillar 2 includes a coordinated system of rules designed to ensure that large (domestic/MNE) groups with a consolidated revenue exceeding EUR 750 million for at least two of the four previous years, are subject to a minimum Pillar 2 effective tax rate of 15%.
What is the QDMTT return?
The form regarding the (Qualified) Domestic Minimum Top-up Tax should be filed on an annual basis within 11 months after the last day of the reporting year in scope of the rules. For in-scope groups with financial years that follow the calendar year, this means the first due date to file the return will be 30 November 2025.
The draft QDMTT return includes the following sections:
I. Identification – information on the Belgian constituent entity and contact person responsible for the filing as well as general information about the Pillar 2 group.
II. Group structure – information about the ultimate parent entity, Belgian group entities (both constituent entities and joint ventures) and excluded entities.
III. Safe Harbours – per Belgian subgroup, information regarding the permanent safe harbour for non-material constituent entities, temporary CbCR Safe Harbours and de-minimis exclusion.
IV. Elections – identification of the elections made per Belgian subgroup (e.g. stock-based compensation expense).
V. Calculation of the Belgian QDMTT – limited number of data points per Belgian subgroup including the Financial Accounting Net Income or Loss, the GloBE Income (Loss), Tax accrued in the financial accounts, Adjusted Covered Taxes and taxes to be reallocated under the QDMTT rules. This section also includes some formulas to enhance the comprehensibility of the calculations.
VI. 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 Pilar 2). Please also refer to our newsflash in this respect.
VII. 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).
To ensure the new form is as clear and efficient as possible, the Belgian tax authorities are seeking valuable feedback. Any feedback can be emailed to pillar2@minfin.fed.be in a Word document by 8 November.
How can we assist you?
We are happy to assist you with:
- Providing any assistance on Pillar 2, including data collection and computations; and/or
- Computing and optimising the advance tax payments to be made for assessment year 2025 in relation to Pillar 2 top-up taxes under the (Q)DMTT and IIR, also considering advance tax payments for Belgian corporate income tax; and/or
- Any assistance with preparing the QDMTT form once the Belgian tax authorities published the final version.
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).
Authors
More news about
- Corporate income tax
- Tax Accounting
- Tax challenges arising from the digitalisation of the economy/Global anti-base erosion (GloBE)
