One year after the implementation of this regulation, we provide an overview of the obligations in Belgium and the developments at European and international level.

Obligations in Belgium

Belgian entities that are part of a group subject to the minimum tax must comply with various administrative and tax obligations. Below is an overview of the main formalities and deadlines.

1. Registration with the Crossroads Bank for Enterprises (CBE)

Groups with Belgian group entities must register with the Crossroads Bank for Enterprises (CBE). This registration is done via a notification form that must be submitted within 30 days after the start of the first reporting year in which the group falls under the scope of the minimum tax.

2. Advance payments

The second step is to assess whether it is useful to make advance payments for the QDMTT or IIR. Although these advance payments are not mandatory, they can be made to avoid increases. The deadlines for these advance payments are the same as those for corporate income tax.

3. Filing of the Domestic Top-up Tax Return (QDMTT)

The return for the domestic top-up tax (QDMTT) must be submitted within 11 months after the end of the financial year.

4. GloBE Information Return

The GloBE Information Return must be filed within 15 months after the end of the financial year. For the first financial year, an exceptional period of 18 months applies.
In principle, this return must be submitted by each Belgian entity, but there are some exceptions:

• Belgian entities can designate one (Belgian) entity to submit the return on behalf of the group in Belgium.
  

If Belgium and the country where the ultimate parent entity is located have an agreement for the exchange of information regarding the application of the minimum tax, the parent entity may submit this return.

European developments

As mentioned earlier, the GloBE return must be submitted in every jurisdiction, unless the ultimate parent entity is located in a country with an information exchange arrangement.

At the end of 2024, the European Commission launched a proposal to organise this at the European level. The so-called DAC9 proposal offers the possibility to file one central, standardised return and introduces a harmonised system for information exchange between tax authorities.

International developments – U.S. and the MAGA policy

In 2021, 136 countries signed the agreement on the minimum tax, including the United States under the leadership of President Joe Biden. However, due to political opposition within the U.S., particularly from Republicans, the minimum tax has not yet been implemented there.

Under the Trump administration, the U.S. withdrew from the agreement and now threatens retaliatory measures against countries that implement the domestic top-up tax (QDMTT).

These measures would include additional levies affecting both companies generating income in the U.S. and private investors holding U.S. stocks.

The big question remains how this situation will evolve and how the EU will respond.