Belgium Issues Draft Law to Implement the OECD Administrative Guidance

On March 6, 2024, the Belgian Government submitted a draft law to Parliament which includes provisions to amend the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ (the ‘GloBE Law).

See our English Translation of relevant provisions of the draft law at: English Translation of the Belgian Draft Global Minimum Tax Amendment Law

As the GloBE Law transposes the EU Minimum Tax Directive into domestic law, amendments must be compatible with the EU Directive before they can be implemented. On November 9, 2023, the Council of the European Union issued a statement in which it said that the European Commission is of the view that the OECD Administrative Guidance is compatible with the Directive.

As such, the purpose of the draft law is to implement various aspects of the February 2023, July 2023 and December 2023 OECD Administrative Guidance. All of the changes are to apply for fiscal years beginning on or after December 31, 2023.