Draft template of Domestic Minimum Top-Up Tax return published

In the context of the Pillar II legislation, the Belgian tax administration (i.e. the FPS Finance) recently published the template for the Qualified Domestic Minimum Top-Up Tax return. The draft template is available in Dutch and French. The final version of the template will soon be published in the Belgian Official Gazette.

In the framework of the 15% minimum taxation rules for large international and domestic groups, also known as Pillar II, several compliance formalities need to be complied with. Previous articles regarding the Pillar II legislation and the relevant compliance can be found here and here. 

The Federal Public Service for Finance recently published the draft template of the Belgian Qualified Domestic Minimum Top-Up Tax (QDMTT). This draft template was published after a public consultation in October 2024 where every stakeholder could provide feedback on the template. The tax authorities aimed to align the template with the OECD GIR-template and the feedback that was received following the public consultation.

It is expected that the final template will be published in the Belgian Official Gazette in short notice, without any (or very small) changes.

The scope of the draft template is limited to the information that is required for the (Q)DMTT and consists of the following main sections:

• Identification (of the Belgian entities, the designated local entity and the MNE-group); 
• Group structure; 
• Safe harbours; 
• Elections; 
• DMTT computation; 
• Prepayments; 
• DMTT liability; 
• Contact person;
• Signature.

The first possible filing deadline for the (Q)DMTT in Belgium is 30 November 2025 (i.e. the last day of the eleventh month following the closing of the reporting year). 
The deadline is 7 months before the first GIR-return filing deadline for the fiscal year 2024, and 1 month before the CbCR-filing deadline.
 
Taxpayers can only submit the DMTT-return if the group is registered for Pillar II/GloBE purposes in Belgium. Information on the Pillar II/GloBE registration can be found in our previous articles.