Global Daily Tax News, Belgium Issues Comprehensive Pillar Two Guidance, (Oct 29, 2025)

Belgium's tax authority has issued new in-depth guidance on the nation's legislation governing the Pillar Two minimum top-up tax on multinational enterprises and large domestic groups.

As an EU member state, Belgium transposed the EU Minimum Tax Directive into national law. This provides that in-scope taxpayers' profits should be liable to a corporate tax rate of at least 15 percent. The rules apply to any group, both domestic and international, with a parent company or a subsidiary situated in an EU member state, if the group's combined annual turnover is at least EUR750m, beginning for fiscal years from January 1, 2024.

Among numerous other things, the guidance, available in French and Dutch, first discusses key definitions and then the scope of the regime, the rules for mergers and demergers, calculation rules, transfer pricing and international tax rules, the rules regarding tax credits, the allocation of profits and losses between group members, capital gains tax rules, the substance-based income exclusion, and safe harbors and transitional provisions.

It covers the rules that apply under the income inclusion rule, the undertaxed profits rule, and the domestic minimum top-up tax, with examples throughout.