Belgium: parliament reviewing draft law for pillar 2 global minimum tax

The Belgian parliament is currently considering the draft bill for implementing the Pillar 2 global minimum tax, as per Council Directive (EU) 2022/2523 of 14 December 2022. The draft bill was submitted to the Parliament on 13 November 2023.

The draft law proposed introducing the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to impose a minimum tax rate of 15% for MNE groups with annual revenue of at least EUR 750 million. The draft law also includes a provision for a qualified domestic minimum top-up tax (QDMTT).

The IIR and QDMTT will be effective for tax years starting on or after December 31, 2023, while the UTPR will apply to tax years commencing on or after December 31, 2024.

Furthermore, on 2 March 2023, Mr. Vincent Van Peteghem, the Belgian Deputy Prime Minister and Minister of Finance first declared a government’s proposal for the Implementation of a global minimum taxation of 15% for MNEs operating in Belgium as part of major tax reforms, effective from 1 January 2024.

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