GloBE Country Guide: Belgium

Summary

Status	Enacted Law
Law	Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ of December 28, 2023. On May 12, 2024, the Belgian Official Gazette published a law which includes provisions to amend the ‘Act on the introduction of a minimum tax for multinational enterprise groups and large domestic groups’ to implement the OECD Administrative Guidance. On October 10, 2025, Belgium issued a Draft Law to amend its Minimum Tax Act. There are a number of technical amendments (which don’t effect the Minimum Tax calculation) as well as administrative amendments. On October 22, 2025, Belgium issued Circular 2025/C/68 which provides detailed guidance on the application of the Pillar 2 rules in Belgium.
Effective Date	Accounting periods beginning on or after December 31, 2023
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, the Transitional UTPR Safe Harbour, QDMTT Safe Harbour and the NMCE Safe Harbour

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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