Yesterday, the Belgian tax authorities announced an additional 1-month extension of the filing deadline for the Qualified Domestic Minimum Top-up Tax (“QDMTT”) return, the Income Inclusion Rule (“IIR”) Top-up Tax return and GIR Notification. For all returns for which the statutory filing deadline falls before 31 October 2026, the deadline has been extended to 31 October 2026.
You can find the official announcement and further details on the official website of the Belgian tax authorities:
QDMTT/IIR; and
The current announcement does not impact the due date for financial year 2025 Pillar 2 compliance. Under the legislation currently in force, the QDMTT return for calendar-year taxpayers remains due by 30 November 2026. However, a draft law transposing DAC9 into Belgian law is currently pending before Parliament. If adopted in its current form, it would align the QDMTT return deadline with the GIR (notification), IIR and UTPR Top-up tax returns deadline, i.e. the last day of the 15th month following the end of the fiscal year. Accordingly, subject to the draft law being adopted without relevant changes, the deadline for a financial year ended on 31 December 2025 would be expected to move to 31 March 2027.
As a reminder, the legal basis for these filing obligations is the Belgian Pillar 2 law of 19 December 2023, which introduced a minimum tax for multinational enterprises and large-scale domestic groups.
We are pleased to support you with the preparation, review and/or filing of the Belgian Pillar 2 Compliance. For more information, please reach out to your regular PwC contact person.
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