Belgium: Introduced Bill to Amend Minimum Taxation Rules under Pillar Two in Belgium

On 6 March 2024, a Bill was introduced into the Belgian Chamber of Representatives aimed at revising the current minimum taxation regulations, as outlined under Pillar Two, which were initially published on 28 December 2023. This Bill introduces several updates, including Safe Harbours in line with the OECD's Administrative Guidance and integrating anti-hybrid arbitrage rules connected to the transitional Country-by-Country (CbyC) Reporting Safe Harbour for transactions post-18 December 2023. Furthermore, the Bill encompasses additional provisions from the OECD's Administrative Guidance, adjustments to align with the EU Directive's terminology, and administrative requirements, alongside establishing a registration requirement in the Belgian Commercial Register for GloBE compliance. The Bill is set to be applicable for fiscal years commencing from 31 December 2023 if adopted.