Belgium Overhauls Pillar Two Tax Rules in New Draft Bill
Belgium has moved to refine its Pillar Two tax rules with a new draft bill submitted to Parliament on 9 October 2025. The proposed changes aim to clarify existing legislation, introduce stricter filing deadlines, and align the system with the Belgian Income Tax Code. Among the key updates are new definitions, reduced statute limitations, and mandatory electronic submissions for all Pillar Two communications.
The draft bill tightens several aspects of Belgium’s Pillar Two framework. One major adjustment limits the definition of a 'group' for tax purposes, restricting Constituent Entities to those consolidated on a line-by-line basis. Joint venture entities will now be treated separately, marking a shift from previous interpretations.
The amendments bring greater clarity to Belgium’s Pillar Two legislation while enforcing stricter compliance measures. With deadlines now firmly established and electronic submissions mandatory, businesses will need to adapt quickly. The changes also ensure closer alignment with the Belgian Income Tax Code, streamlining taxable periods and return requirements.
