Under the Pillar 2 legislation, Belgium opted to apply the tax advance tax payments schedule applicable for corporate income tax to Pillar 2 top-up taxes under the Qualified Domestic Minimum Top-up Tax (QDMTT) and Income Inclusion Rule (IIR).
If no advance tax payments are made in the course of the financial year, a surcharge of 6,75% on the top-up tax due (QDMTT or IIR) will be imposed with respect to assessment year 2027 (i.e. financial years closing as per 31 December 2026 or in 2027 if the financial year closes prior to 31 December). To reduce or avoid the surcharge, quarterly payments entitling the company to a credit can be made. The credit can be offset against the surcharge. The sooner the advance tax payment is made, the higher the tax credit. We also recent to our recent newsflash on the advance tax payments for corporate income tax.
The first advance tax payment, benefiting from a 9% bonification, is expected by 10 April 2026, for a financial year covering 12 months and ending on 31 December 2026 (otherwise in principle by the 10th day of the fourth month of the financial year).
What’s new?
On 9 February 2026, the tax authorities published an update on their website detailing modifications to the structured communication system for the IIR advance tax payments for 2026. When making an IIR prepayment, each entity should utilize the structured communication available on MyMinfin, specific to each taxpayer, or generated through the tool provided by the tax authorities based on the entity’s company number. They also confirmed that constituent entities wishing to make an advance tax payment for the IIR must do so individually.
Please note that the above applies exclusively to IIR advance tax payments. The current procedure remains unchanged for QDMTT advance tax payments.
How can PwC help?
We are happy to assist you with:
- Computing and optimizing the advance tax payments to be made for assessment year 2027 in relation to Pillar 2 top-up taxes under the QDMTT and IIR, also considering advance tax payments for Belgian corporate income tax; and/or
- Preparing and filing the Belgian QDMTT return due by 30 June 2026 in relation to financial year ended 31 December 2024 (or later as long as the statutory filing deadline falls before 30 June 2026) as a result of the extension of the deadline. Note that for calendar financial years, a Belgian QDMTT return is also expected with respect to financial year 2025 by 30 November 2026, as per the statutory filing deadline of 11 months after the last day of the reporting year.
For more information or advice, please reach out to Pieter Deré, Maxim Allart or your regular PwC Contact.
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