Document background
The Global Minimum Tax Agreement is essential for multinational enterprises operating in Belgium that fall within the scope of OECD Pillar Two rules and EU Directive 2022/2523. This document becomes necessary when a multinational group has annual revenue exceeding 鈧750 million and needs to ensure compliance with the 15% global minimum tax requirement. The agreement provides a comprehensive framework for implementing these requirements under Belgian law, including detailed methodologies for calculating effective tax rates, procedures for top-up tax payments, and mechanisms for information sharing between group entities and tax authorities. It incorporates specific Belgian legal and administrative requirements while maintaining alignment with international standards and EU directives. The document is particularly crucial for groups with complex international structures requiring clear guidance on their Belgian tax obligations within the global minimum tax regime.
