Belgium extends Pillar Two registration for large-scale domestic groups not making advance payments in 2024

July 2024

What happened?

Today the Belgian Tax Authorities published an “administrative tolerance,” extending the deadline for certain taxpayers within the scope of the requirement to register under Belgium’s Pillar Two legislation.  The extended deadline will be applicable to multinational and large-scale domestic groups that do not (intend to) make advance payments in 2024 for the Belgian domestic top-up tax or the Income Inclusion Rule (IIR). These groups are permitted to submit their notification for registration to the Crossroads Bank for Enterprises on or before September 16, 2024. 

Why is it relevant?

This administrative tolerance does not apply to MNE groups and large-scale domestic groups who (wish to) make advance payments in 2024. For those groups, the deadline to submit the form remains as 30 days after the first day of the first fiscal year for which the group is in scope of Pillar Two (for groups with a fiscal year starting on or before June 14, 2024, this deadline remains July 15, 2024). 

 

‘FY’ refers to the first FY for which Pillar Two applies to the Belgian group entity/ies

 

FY starting on or before 

June 14, 2024

 

FY starting between June 15 and Aug 17, 2024

 

FY starting from Aug 18, 2024

 

Group intends* to make prepayments in 2024

 

July 15, 2024

 

30 days after the start of the first fiscal year

 

 

 

 

 

 

30 days after the start of the first fiscal year

 

 

Group does not intend* to make prepayments in 2024

 

 

 

September 16, 2024

 

 

September 16, 2024

 

Action to consider:

Taxpayers should remain aware of the varying Pillar Two registration deadlines as jurisdictions continue to announce (and change) them. This extension of the Belgium registration deadline should provide much needed relief to many taxpayers who were facing a tight deadline for compliance. 

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Ed Geils

Ed Geils

Global and US Tax Knowledge Management Leader, PwC US

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