On 22 October 2025, Belgium’s Federal Public Service Finance issued the Circular Letter 2025/C/68 providing extensive administrative guidance on the Belgian minimum tax regime for multinational enterprise (MNE) groups and large domestic groups (“the Pillar 2 Circular Letter”). The document has approximately 400 pages and is available in Dutch and French.
It provides administrative guidance with respect to the Law of 19 December 2023 introducing a minimum tax for multinational enterprises and large domestic groups (also referred to as the “Pillar 2 Law”). The Circular Letter does not modify the Law, but provides detailed administrative interpretations, calculation methods, examples, and operational clarifications.
The document confirms that the Belgian tax administration adheres to the relevant sections of the OECD’s “Consolidated Commentary to the Global Anti-Base Erosion Model Rules” and “Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) Examples,” as published on 25 April 2024, as well as the EU’s “Frequently Asked Questions on the Pillar Two Directive”, as published on 22 December 2023.
Key topics (not) addressed in the Pillar 2 Circular Letter:
- It provides details regarding the application of the Transitional CbCR Safe Harbour in specific cases such as stateless entities, Pillar 2 joint ventures, and investment entities.
- It describes how the economic cost of Belgian QDMTT or UTPR can be split between multiple Belgian entities through tax-neutral payments and provides an example.
- It reconfirms the ‘Qualified’ status of the Belgian R&D Tax Credit following the shorter refund period (from 5 to 4 years) and the option not to claim the full R&D Tax Credit and transfer the ‘excess’ to a following fiscal year.
- With this document, the Belgian tax authorities clarify that, in cases where the Pillar 2 Law or the EU Pillar 2 Directive differ from the OECD’s Model Rules, only the Pillar 2 Law and the EU Pillar 2 Directive are legally binding and applicable.
- The Circular Letter refers to the OECD Consolidated Commentary published on 25 April 2024, meaning that certain elements of guidance contained in the Consolidated Commentary published on 9 May 2025 have not yet been considered.
- The Circular Letter does not include any changes to the deadline of the first Belgian QDMTT return, which is still expected to be 11 months after the end of the fiscal year, i.e. 30 November 2025 for calendar year taxpayers). The Belgian QDMTT return remains a draft to this day, and updates are still to be expected in the final version. Please refer to our previous news alert on the draft return.
How PwC can help
We would be pleased to review the impact of the Pillar 2 Circular Letter on your specific situation.
We would also be happy to assist you with the preparation, review and/or filing of the Belgian QDMTT return. As its deadline is only in 5 weeks (for financial years ended 31 December 2024), now is the time to align on the responsibilities within your group and start gathering the necessary data to ensure that you will be ready by the time the final Belgian QDMTT return, as well as the administrative clarifications, are released.
For more information or advice, please reach out to Pieter Deré, Evi Geerts, Maxim Allart or your regular PwC Contact.
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