Belgian Pillar 2 update - Belgium extends the filing deadline of the QDMTT return

The extended filing due date is applicable for Belgian constituent entities subject to the Belgian Pillar 2 rules for reporting periods starting at earliest on 31 December 2023 and ending at earliest on 1 January 2024 and at latest on 30 June 2025.

The due date of 30 June 2026 is as such applicable for all Belgian constituent entities of an MNE group whose statutory filing deadline falls before 30 June 2025.

The extended deadline of 30 June 2026 aligns with the first GloBE information return (“GIR”) deadline, as well as with the QDMTT return filing due date in multiple other jurisdictions, a.o. our neighboring countries France, the Netherlands, Germany, where the first QDMTT return needs to be submitted per 30 June 2026.

In accordance with Belgian Pillar 2 domestic tax legislation, the Belgian QDMTT return should initially have been filed by the last day of the 11^th month following the end of the reporting year, i.e. by 30 November 2025 in case of 31 December 2024 year-end. If an MNE group’s fiscal year ended on 30 June 2025, the first Belgian QDMTT return would have need to be filed ultimately by 31 May 2026.

Call for action

Corporate groups subject to Pillar 2 that have corporate entities or permanent establishments in Belgium are thus allowed some additional time to gather the necessary datapoints from their qualifying CbC reporting statements for the Belgium QDMTT return to ensure timely compliance.

The Belgian tax administration has not made the XML conversion tool available for filing. As a result, Belgian in-scope taxpayers, who made significant efforts over the last weeks to meet the initial filing obligation and are ready to comply, are unable to introduce the QDMTT return and should await the publication of further technical guidelines / QDMTT return (which is expected in 2026).

Based on the current position of the Belgian tax administration, the Belgian QDMTT filing obligation would still apply even if Safe Harbour relief is applicable.

Forvis Mazars in Belgium assistance

Your Belgian Forvis Mazars team will actively follow up in the next weeks and alert you once the XML conversion tool is accessible. In the meantime, we do not advise to delay the QDMTT return preparation for another 7 months.

Upon your request we would be pleased to assist you with a.o.:

• Performing a Safe Harbour relief assessment based on qualifying 2024 CbC Report data for the Belgian jurisdiction;
• Reviewing the relevant datapoints and assist with the Belgian QDMTT return preparation via our automated datapoint tracker (XML conversion tool)