As announced by the Belgian tax authorities today, starting September 2, 2024, MNO groups and large domestic groups can initiate their advance payments for top-up taxes under Pillar 2, provided they have obtained their Pillar 2 group number following the mandatory notification (P2-CBE-NOT form; click here for more details). The advance payments for the minimum tax are regulated in the Royal Decree of 7 July 2024 (publication in the Belgian Official Gazette on 16 July 2024).
What are Pillar 2 advance tax payments?
As mentioned before, Belgium introduced the global minimum tax for multinational companies and large domestic groups (‘Pillar 2 law’) for Fiscal Years starting on or after 31 December 2023. The law 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%.
In the Pillar 2 law, Belgium opted to apply the tax prepayment schedule applicable for corporate income tax to Pillar 2 top-up taxes under the (Qualified) Domestic Minimum Top-up Tax ((Q)DMTT) and Income Inclusion Rule (IIR).
In the event that no advance tax payments would be made, a surcharge of 9% of the top-up taxes will be due. Any prepayments made during the financial year can be credited against this surcharge as follows:
- 12% = payment received by the Belgian tax authorities no later than the 10th day of the fourth month (10 April at the latest for a financial year ending on 31 December)
- 10% = payment received by the Belgian tax authorities no later than the 10th day of the seventh month (10 July at the latest for a financial year ending on 31 December)
- 8% = payment received by the Belgian tax authorities no later than the 10th day of the tenth month (10 October at the latest for a financial year ending on 31 December)
- 6% = payment received by the Belgian tax authorities no later than the 20th day of the last month (20 December at the latest for a financial year ending on 31 December).
However, a tolerance is provided on the basis of which all advance tax payments will be deemed to have been made during the first quarter (i.e. a credit of 12% will be applied on the amounts paid) for all payments made before 20 December 2024.
How can you make Pillar 2 advance tax payments?
Advance payments can be made via:
- MyMinFin, using the “VA Pillar 2” module, or
- through a bank transfer. Note that there is one bank account for the (Q)DMTT and one for the IIR. The bank transfer has to include a specific structured communication based on the Pillar 2 group number and can be made by any group constituent entity for the first year (as from next year, a notification will need to be made).
Further details on the advance tax payments and how to execute them, as well as contact details for support with any questions or issues, can be found on the Pillar 2 webpage and the Pillar 2 e-service.
How can we assist you?
We are happy to assist you with:
- Computing and optimizing 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
- Providing further guidance on how to access/use the specific module on the MyMinFin platform; and/or
- Requesting the Pillar 2 group number via the mandatory Pillar 2 notification (P2-CBE-NOT form); and/or
- Providing further assistance on Pillar 2, including data collection and computations.
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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