MoF Amends Advance Tax Payment Procedure for IIR Top-Up Tax in Belgium
The Ministry of Finance has announced changes to the procedure for advance payment of the income inclusion rule (IIR) top-up tax under the Pillar Two global minimum tax framework for multinational enterprises (MNEs) and large domestic groups. The new procedure has been applicable since January 2026.
As a result, taxable entities wishing to make an advance payment for the IIR top-up tax must now do this for each group entity. To make advance payments, they can use the structured communication available on MyMinfin at the entity level (per taxpayer). The payment can also be transferred using the payment tool on the tax administration's website based on the entity's enterprise number or entity's bis identification number (for companies not registered in Belgium) provided by the FPS Finance.
The full text of the announcing press release of 9 February 2026 is available here (in Dutch) and here (in French).
Note: Under the Pillar Two framework, multinational enterprises (with revenues exceeding EUR 750 million) pay a minimum tax of 15% on the income arising in each of the jurisdictions where they operate.
The IIR is the primary mechanism for ensuring a global minimum effective tax rate of 15%. Under the IIR, a top-up tax is imposed at the level of the ultimate parent entity of a group where the profits of that group are not subject to the 15% minimum effective rate. Where the country of the ultimate parent entity does not apply an IIR, the IIR must be applied at the level of another parent entity in the group, further down in the ownership chain.
Report from Dr René Offermanns, Principal Associate, IBFD. Follow our reporting on this via our daily Tax News Service (subscribers only).