Belgium | CIT | Transfer Pricing
July 02, 2024
Belgium: Administrative Tolerance for 2024 Moves Registration Requirement under Pillar 2 Regulations
Only applicable to groups that will not make Belgian advance payments for the 2024 QDMTT and/or 2024 IIR
Multinational enterprises (MNEs) and large-scale domestic groups with consolidated annual revenues exceeding EUR 750 million and a Belgian nexus must register with the Federal Public Service Finance (FPS Finance) by filing a Pillar Two Notification Form.
Upon filing, the FPS Finance will issue a Pillar Two identification number, enabling the taxpayers to make advance tax payments under Belgium’s Qualified Domestic Minimum Top-up Tax (QDMTT) or Income Inclusion Rule (IIR) regime. This identification number also facilitates the submission of Pillar Two-related notifications and tax returns.
FILING DEADLINES
The Notification Form must be submitted by the later of the following dates:
- Within 30 days from the start of the financial reporting year in which the MNE group or large-scale domestic group falls within the scope of Pillar Two.
- Within 45 days following the publication of the Royal Decree of 15 May 2024 in the Belgian Official Gazette. Given the publication date of 29 May 2024, the initial deadline was set for 13 July 2024 but has been extended to the first business day thereafter, 15 July 2024.
ADMINISTRATIVE TOLERANCE FOR 2024
On 2 July 2024, the Belgian Tax Authorities announced that in-scope groups not making Belgian advance payments for the 2024 QDMTT and/or 2024 IIR may file their Notification Form up to and including 16 September 2024. However, this extension does not apply to groups intending to make advance payments for the Belgian QDMTT and IIR in 2024.
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