Action required for Pillar Two Groups with constituent entities in Belgium

We would like to draw your attention to information shared by Deloitte Belgium, according to which guidance pertaining to the application of the Pillar Two rules in Belgium was published on 29 May 2024. The guidance creates additional compliance obligations for the MNE Groups in scope having constituent entities in Belgium, for which due to short filing deadlines immediate action is required.

The full information published by Deloitte Belgium is available here.

Based on our understanding, MNE Groups that are in scope of Pillar Two must submit an online notification to the Belgian tax authorities, containing inter alia information on the group, the consolidated financial statements and individual constituent entities. Afterwards, the MNE Groups shall obtain a Pillar Two identification number from the local trade register.

For MNE Groups for which the first Pillar Two-Reporting Year has already started (e.g. calendar year groups), the Pillar Two notification must be submitted no later than 13 July 2024. In all other cases the notification must be made no later than 30 days after the start of the fiscal year for which the MNE Group falls within the scope of the Pillar Two rules for the first time.

Considering the short filing deadline (13 July 2024) and the data required, our Belgian colleagues recommend taking immediate action in order to fulfil this compliance obligation in due time. If you wish, we are happy to get in touch with our Belgian colleagues to support you in this matter.