Belgian Pillar Two: more time to file, much less room for error

The Belgian QDLTT dead line moves

The QDMTT return is now due by the end of the 15th month following the fiscal year-end or the 18th month for fiscal years beginning no later than 31 December 2024.

This finally aligns the Belgian QDMTT timetable with the GIR timetable.

IIR and UTPR now clearly separate returns
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The law now reflects the filing process already applied in practice.

The relevant return is required where Belgium has taxing rights under the IIR or UTPR, even where the ultimate amount payable may be nil.

This creates an essential distinction: No Belgian taxing right is not the same as a Belgian filing with no tax due.
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DC9 brings automatic GIR exchange with the EU

Belgium will exchange the relevant parts of the GIR with the competent authorities of the other EU Member States.

Central filing therefore becomes operationally more important, but groups must still understand which information will reach which jurisdictions.

The penalty risk becomes much more concrete

The new statutory ranges include:

▪️ EUR 1,250 to EUR 62,500 for an incomplete or incorrect return or GIR;
▪️ EUR 2,500 to EUR 125,000 for a late or missing filing; and
▪️ up to EUR 250,000 where fraudulent intent or an intention to cause harm is established.

The detailed scale must still be determined by royal decree. The law also allows the authorities to waive a fine where there is no bad faith.

My takeaway : Belgium is moving from the implementation phase to the enforcement phase.

The additional time is welcome. But it should not be treated as a pause. Groups should use it to establish, entity by entity: who must file; which return must be filed; where the relevant data will come from; who will review and validate them; and whether a nil liability still leaves a filing obligation.

Because under Pillar Two, the most dangerous assumption may now be:
No tax due = nothing to file​
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Has your Belgian Pillar Two filing matrix already been updated?