Cross-border Tax Talks

Pillar Two in Belgium: First out of the gate 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pieter Dere, Tax Partner in PwC Belgium, part of PwC’s International Tax and Transfer Pricing Group, and PwC Belgium’s Pillar Two leader. Doug and Pieter cover the latest Pillar Two developments in Belgium, including how Belgium is incorporating the latest Pillar Two administrative guidance, how tax authorities are preparing, advance tax payments, registration requirements, the Qualified Domestic Minimum Top-up Tax (QDMTT) return, the interaction of the Belgium patent box regime with Pilar Two, and the constitutionality of the Undertaxed Profits Rule (UTPR), among other topics. 

Timestamps:

• 1:20 – Where can listeners find Pieter’s ‘Tax Bites’ podcast? 
• 2:50 – Where is Belgium in the Pillar Two process? 
• 4:35 – Have the OECD administrative guidance packages been incorporated into the Belgium domestic legislation? 
• 6:00 – How could Belgium implement retroactive Pillar Two rules? 
• 8:45 – Will Belgium incorporate any administrative guidance released by the OECD before the end of 2024? 
• 10:20 – What accounting standard is Belgium applying for its QDMTT? 
• 11:30 – How are the Belgian tax authorities preparing to audit companies under Pillar Two? 
• 12:15 – What is the application for payment under the Belgium UTPR? 
• 13:50 – What are Pillar two advance tax payments in Belgium? 
• 16:00 – When is the QDMTT return due and when will Belgium publish the actual form? 
• 17:40 – When is Belgium’s Pillar Two registration deadline? 
• 20:15 – What types of information are required in the Pillar Two registration? 
• 25:50 – Are there any issues with Pillar Two and the Belgium patent box regime? 
• 27:45 – How are taxpayers impacted by the timing pressures of compliance? 
• 29:05 – Where is Belgium in the process of ‘qualification’ an income inclusion rule, QDMTT, or incentives? 
• 31:30 – Can you explain the recent Belgian court case challenging the constitutionality of the UTPR? 
• 36:05 What advice does Pieter have for Pillar Two taxpayers in Belgium?  

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