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ARTICLE · 21 NOVEMBER 2023

Belgium Publishes Draft Bill Implementing Pillar Two

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On 13 November 2023, a draft bill implementing Pillar Two was submitted to Parliament in line with the EU directive of 14 December ensuring a global minimum tax (the Directive).

BelgiumTax
Linda Brosens
Linda Brosens
Nicolas Lippens
Nicolas Lippens

On 13 November 2023, a draft bill implementing Pillar Two was submitted to Parliament in line with the EU directive of 14 December ensuring a global minimum tax (the Directive). The draft bill foresees that the rules enter into force on 31 December 2023 and apply to fiscal years starting on or after 31 December 2023, thereby safeguarding a timely transposition of the Directive.

Some guidelines and solutions released by the OECD after the adoption of the Directive in December 2022 are considered, including the transitional safe harbours based on country-by-country reporting (CbCR) data.

Background

The OECD's Pillar Two project aims to ensure that Multinational Enterprises (MNE) groups meeting the EUR 750 million consolidated revenue threshold are always subject to a minimum corporate taxation of 15%. Much progress has been made in the past years:

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