Belgium Issues an Updated Draft QDMTT Return and XSD Schema

On March 23, 2026, Belgium’s tax administration released an updated draft domestic top-up tax return, together with updated draft explanatory notes, a revised draft XSD, a separate XSD for language, phone and country codes, and an updated XML test tool.

The release covers the Belgian QDMTT return and provides that both the form and the XML materials are still informational only until they are finalised and published in the Belgian Official Gazette. Belgium has already granted filing relief, so QDMTT returns for reporting years beginning on or after December 31, 2023 and ending no later than June 30, 2025 are due by June 30, 2026.

Article 51(2) of the Belgian Pillar Two Law (Law of December 19, 2023) requires an annual QDMTT return containing the identification of Belgian group entities, group-structure information, the data needed to compute the domestic top-up tax, an overview of elections made for Belgium, and the enterprise number used for prepayments. Article 52 fixes the statutory filing deadline at the last day of the eleventh month following the reporting-year end.

The explanatory notes to the form state that the QDMTT return was aligned with the GIR where possible and that certain input values were harmonised with GIR codes, but they also say expressly that, in the event of conflict, Belgian law, circulars and explanatory notes prevail over GIR references.

Changes in the Updated QDMTT Return

Belgium says this latest update added an abbreviation on page 1, deleted boxes 4.2.a.2.i and 4.3.3.i, added statutory references to a number of section-5 boxes, and adapted the XML test tool to the amended XSD.

The more structural changes had already been announced on the previous January 6, 2026 update. Box 1.1.4 was added (Belgian tax number of a company dissolved without liquidation), bank-account and group-structure data had to be completed every year even if unchanged, box 4.2.b.1 was brought into the XSD, section 4.3 entity elections became repeatable in the XSD, and Belgium announced that the Article 13 §5 election (forex hedge election) had become a five-year election in box 4.3.3.f.

Form Overview

On the form itself, Belgium has made several domestic choices. The return must be filed electronically via MyMinFin. Where multiple Belgian taxpayers are subject to the QDMTT, Belgium requires one common return for all Belgian tax-liable entities of the group. The notes also require that the group name used in the form match the name used for the Belgian KBO/CBE registration, that the Pillar 2 identification number (FIN) be reported, and that the filing entity’s IBAN and BIC always be included.

If the consolidated financial statements are prepared in a non-euro presentation currency, Belgium wants the exchange rate to be reported with the same number of decimal places as used by the ECB. Box 1.1.4 is a Belgian nuance: it asks for the Belgian tax number of a company dissolved without liquidation, and the notes explain how that box is used in merger, split and similar successor situations.

Section 2 is equally specific. The reference date for the group-structure disclosure is the last day of the reporting year. The UPE must always be reported, even if it is not Belgian. Ownership percentages are rounded to two decimals but then reported in the form and XML as a decimal between 0 and 1, not as a percent sign value.

A Belgian permanent establishment is shown by referencing the head office and reporting 100% ownership. Natural persons are not reported as entities for these purposes, and holdings of excluded entities or outside-group entities may need to be reported on an aggregated basis rather than owner by owner. 

Corrected Elections

In the current draft, Article 13 §3 (capital gain carry back election)  remains an annual jurisdictional election in box 4.2.a.1.a; Article 13 §6 (Debt release election) remains an annual entity election in box 4.3.2.b; and Article 13 §5 (forex-hedge election) is now a five-year entity election (as opposed to an annual election) in box 4.3.3.f. The Belgian XML concordance table maps it to QdmttBody/SubGroup/Elections/EntityElections/EntityFiveYearElections/Art13Paragraph5, and the OECD XML user guide describes the corresponding OECD election the same way and the same length: a five-year election for FX gains or losses attributable to hedging. This reflects the updated law.  The December 19, 2025 amending law changed Article 13 §5 and added it to Belgium’s five-year list in Article 58, removed it from Article 59’s annual-election list, and made that change effective for reporting years beginning on or after 31 December 2023.

Deleted Boxes