Pillar Two in Belgium
Belgium has implemented OECD Pillar Two through Loi du 19 décembre 2023 / Wet van 19 december 2023. Each applies to fiscal years beginning on or after the respective date: the IIR from 2023-12-31, the QDMTT from 2023-12-31, the UTPR from 2024-12-31.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | Fiscal years beginning on or after 2023-12-31 | In force OECD qualified |
| UTPR — Undertaxed Profits Rule | Fiscal years beginning on or after 2024-12-31 | In force OECD review pending |
| QDMTT — Qualified Domestic Minimum Top-up Tax | Fiscal years beginning on or after 2023-12-31 | In force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Loi du 19 décembre 2023 / Wet van 19 december 2023 — 다국적기업그룹 and 대규모 국내그룹에 대한 최저세 introduction — EU Directive 2022/2523 transposition. 2023-12-14 가결, Belgisch Staatsblad promulgated
- IIR · QDMTT — 2023-12-31 in force from fiscal years beginning on or after the date shown
- UTPR — 2024-12-31 in force from fiscal years beginning on or after the date shown
Practical implications
MNE groups parented in Belgium are subject to the IIR for fiscal years beginning on or after 2023-12-31. Where a subsidiary's jurisdictional effective tax rate (ETR) falls below 15%, top-up tax is computed and paid in Belgium (as the jurisdiction of the parent entities), and the group must also file the GloBE Information Return (GIR).
MNE groups with constituent entities in Belgium are subject to Belgium's QDMTT for fiscal years beginning on or after 2023-12-31. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2023-12-14: Belgium 의회 가결, Belgisch Staatsblad promulgated — IIR · QDMTT in force
Related terms
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- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- Service Public Fédéral Finances (SPF Finances, Belgium 연방Ministry of Finance) — Pillar Two guidance. finance.belgium.be
- Belgisch Staatsblad / Moniteur belge — Belgium 공식 official gazette. www.ejustice.just.fgov.be
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 벨기에). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.