Belgian committee approves DAC9 and QDMTT return deadline bill

The Belgian Chamber of Representatives’ Finance and Budget Committee has unanimously approved a bill that would transpose DAC9, create the domestic machinery for the automatic exchange of GloBE Information Returns and permanently align the Belgian qualified domestic minimum top-up tax return deadline with the main Pillar Two filing timetable.

The committee report, Doc. 56 1719/002, records that the committee considered the bill on 23 September 2026 and adopted it unanimously, subject to legislative and linguistic corrections. The report and the committee-adopted text, Doc. 56 1719/003, are dated 2 October. This is not yet enacted legislation: plenary approval, Royal assent and publication in the Belgian Official Gazette remain necessary. Article 24 of the committee text would bring the law into force on the day of that publication.

The development is distinct from Belgium’s recent administrative extensions. The tax authorities have allowed specified QDMTT and IIR returns, and specified GIR-filing-entity notifications, to be filed by 31 October 2026. The bill instead changes the underlying statutory QDMTT return deadline for future periods and introduces an 18-month transitional rule for fiscal years beginning no later than 31 December 2024.

The headline QDMTT deadline change

Article 19 of the committee-adopted text would replace Article 52 of the Law of 19 December 2023. The ordinary deadline for the Belgian domestic top-up tax return under Article 50(1) would move from the last day of the eleventh month after the fiscal year-end to the last day of the fifteenth month.

For a fiscal year beginning no later than 31 December 2024, the proposed transitional deadline is the last day of the eighteenth month after the fiscal year-end. The test turns on when the fiscal year begins, not simply the assessment year or the date on which the return is filed.

The distinction between statute and administrative tolerance is important. For the earliest calendar-year filing cycle, the current 31 October 2026 administrative deadline remains later than the proposed 18-month statutory deadline. For a calendar fiscal year ending 31 December 2025, however, the proposed 15-month rule would move the statutory deadline by four months, from 30 November 2026 to 31 March 2027.

DAC9 central filing and targeted exchange

Articles 3 to 14 would implement the DAC9 exchange framework in the Belgian Pillar Two law. The bill defines the information return, its general section and jurisdictional sections, and distinguishes implementing Member States from Member States applying only a QDMTT. It also confirms that a Belgian ultimate parent entity or Belgian designated filing entity may file the group’s information return under the central-filing mechanism. A Belgian filer would identify through the FPS Finance electronic platform the relevant sections and Member States to which the information is to be disseminated. (Committee text, Articles 3–4.)

The dissemination rules follow the DAC9 targeted approach. Implementing Member States receive the general section where the UPE or constituent entities are located. A QDMTT-only Member State receives the general section without the high-level summary, where the specified nexus exists. Jurisdictional sections go to Member States with taxing rights for the jurisdiction concerned, subject to the special limitation for a UTPR jurisdiction with a zero UTPR percentage. The Member State of the UPE receives all jurisdictional sections. (Article 8, proposed Article 62/4.)