The Belgian parliament adopted a new Pillar II law on 2 May 2024. This law, which replaces the previous version adopted on 19 December 2023, includes provisions from the OECD/G20 Inclusive Framework on BEPS issued in 2023 and corrects errors in the original Pillar II law. Furthermore, the law modifies the Belgian innovation income deduction regime (IID) to maintain its effectiveness for groups subject to the Pillar II legislation in Belgium. Without these changes, the IID’s benefits would have been partially lost due to a top-up tax payable by groups with a GloBE tax rate in Belgium lower than 15%.The new law will enter into force from the same dates as the original law: the qualified domestic minimum top-up tax (QDMTT) and income inclusion rule (IIR) from 1 January 2024, and the undertaxed payments rule (UTPR) from 1 January 2025.
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