Belgian R&D Tax Credit To Be Aligned with Pillar Two and US GILTI Rules

The draft bill implementing the Pillar Two rules into domestic law in Belgium amends two key elements of the Belgian R&D tax credit. First, the unused R&D tax credit will be reimbursed after four (instead of five) years to comply with the QRTC definition under Pillar Two. Furthermore, the possibility to opt out of the automatic compensation of the R&D tax credit solves the negative interplay with the US GILTI rules. This note comments on these amendments.