1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force? 
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
  7.  Further comments

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Belgium
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

Pending implementation of the EU directive – before 31 December 2023. The draft bill is expected to be presented to parliament in September.

3. Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?

The timetable for publication of the administrative guidelines is not yet known. It is likely that guidelines will be published in 2024. A designated service team will be installed within the Belgian tax authorities.

4. When will the Income Inclusion Rule (IIR) come into force? 

2024.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

2025.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

Yes, in 2024. Advance tax payments can be made as of Q1 2024.

7. Further comments

The draft implementation Act provides that no advanced tax rulings will be issued by the Belgian ruling commission on the application of Pillar Two in Belgium (before or after it has been implemented under Belgian law).