Belgium Issues a Royal Decree for its 2024 QDMTT Return

On 1 June 2026, the Belgian Official Gazette published the Royal Decree of 25 May 2026 determining the model QDMTT Return  for assessment year 2024. Article 1 fixes the statutory model of the Belgian QDMTT return by reference to the annexed form.

The annex is headed ‘Return for the domestic top-up tax – assessment year 2024’ and applies (in its own wording), to reporting years closed on 31 December 2023 or in 2024 before 31 December. 

Legislative Background

Under Article 50 of the Law of 19 December 2023, Belgian constituent entities must file a domestic top-up tax return annually, subject to the possibility of a designated local entity filing on behalf of Belgian group entities. Article 51 §1 provides that the return must be made on a form whose model is determined by the King. Article 52,  sets the ordinary filing deadline as the last day of the eleventh month following the close of the reporting year (subject to an extension to September 30, 2026 for the first wave of Pillar Two filings – see below).

What the assessment year 2024 form requires

The annexed form requires a structured Belgian Pillar Two data package. Its first section asks for the identification of the taxpayer, the filing entity, address details, contact details and banking information. The form also asks for information on the group, the ultimate parent entity, the reporting year and the consolidated financial statements.

The return then addresses the Belgian group. It requests information on Belgian group entities, joint ventures, joint venture affiliates and excluded entities, as well as ownership and structural information relevant to the Belgian Pillar Two analysis.

A separate section deals with safe harbours and exclusions, including a safe-harbour election and the Belgian de minimis exclusion under Article 29 of the Pillar Two law. The form also contains an elections section, distinguishing annual elections from multi-year elections. The elections listed include, among others, elections relating to the substance-based income exclusion, stock-based compensation, the realisation principle, intra-group transactions, qualifying loss treatment and simplified calculations for certain non-material constituent entities.

The computational sections require figures for net financial accounting income or loss, QDMTT net GloBE income or loss, financial accounting tax, adjusted covered taxes, adjusted domestic covered taxes and the domestic top-up tax rate. It then requires the domestic top-up tax computation both in the presentation currency and in euros, together with details of adjusted domestic covered taxes.

Finally, the form addresses Belgian Pillar Two advance payments and the final tax computation. It asks for domestic top-up tax advance payments by quarter, the possible use of excess corporate income tax or non-resident corporate income tax advance payments under Article 30 §2 of the Belgian Pillar Two law, and the resulting amount due or refundable. The return closes with contact-person details and a signature declaration.

Note that while the final QDMTT Return has therefore been issued, and filing will be via the Belgian MyMinfin e-platform, the specific filing platform is not yet open.

Filing Deadline