On 8 June 2026, Belgium’s Federal Public Service Finance clarified the OECD approach to the centralized filing and exchange of GloBE Information Returns under Pillar Two. The guidance confirms that jurisdictions participating in the framework, including Belgium, will generally not impose penalties or require local filings where multinational groups complete eligible centralized filings by the applicable deadline. It also outlines procedures where information is not exchanged on time and confirms that the approach extends to certain EU countries still implementing the relevant reporting framework.
On October 23, 2025 Belgium’s tax authority published online the Circular 2025/C/68, guiding on the applicability of OECD’s 15% global minimum tax for large multinational groups. The guidance, among others, explains the administration aspects of the income inclusion rule, qualified domestic top-up tax, and undertaxed profits rule. Also, it clarifies the treatment of R&D tax credits and controlled foreign corporations.
To access the Circular, click here.