Deadline Pillar 2 prepayments : 20 december 2024
Belgium introduced the global minimum tax for multinational enterprises (MNE) and large domestic groups (law of 19 December 2023).
As in corporate taxation, Belgium has introduced a similar system of prepayments for QDMTT and IIR purposes. These prepayments are not mandatory, but a tax increase may be avoided if (sufficient) prepayments are made. The tax increase amounts to 9% (for financial year 2024).
To do:
First of all, MNE groups and large domestic groups should assess whether QDMTT or IIR would be due in Belgium. The case being, prepayments can be considered and these can be made from 2 September 2024 until 20 December 2024 via the ‘MyMinfin’ platform (module VA Pillar 2) or by bank transfer. If the taxpayer chooses to complete the prepayment via bank transfer, the following formalities still need to be taken into account:
- There is a different bank account for the QDMTT (BE79 6792 0023 0733) and for the IIR (BE68 6792 0023 0834).
- A specific structured communication must be filled in. This is available on MyMinfin (at group level) or generated with the tool provided by the FPS Finance based on the group's enterprise number.
- Preferably, the prepayments are made via a bank account in the name of the group entity making the advance payment on behalf of the group.
Please note that the payment has effect on the value date of crediting (Art. 2 Royal Decree 7 July 2024). This means that the payment must have reached the Prepayments Department by 20 December 2024 at the latest. The prepayments that are as such dated after that deadline are no longer taken into account for this quarter, but will be taken into account for the next quarter.
It is also important to take into account that the group has made the necessary notification with the FPS Finance for its registration in the CBE (‘Crossroads Bank for Enterprises’) and has received the enterprise number for the group via FPS Finance. More information on this can be found in the following article: Tiberghien - Pillar 2 in Belgium - action required before 13 July 2024.
