Belgium: Practicalities on Notification Requirement for In-Scope Groups Under Belgian Pillar Two Rules

Multinational enterprise (MNE) groups and large Belgian domestic groups with a presence in Belgium are required to submit an extensive notification form to obtain a Pillar Two group registration number from the Belgian trade register, known as the Crossroad Bank for Enterprises (CBE). This mandatory registration is part of Belgium's Pillar Two rules.

Key Deadlines for Submission

Affected entities must adhere to a strict submission deadline, which is determined by the later of the following:

• At least 45 days from the publication of the royal decree of May 15, 2024, in the Belgian official gazette (publication is still pending).
• 30 days after the start of the group's first Pillar Two reporting year.

Entities need to be prepared to act promptly once the royal decree is published to ensure compliance with these deadlines.

How to Fill in the Belgian Pillar Two Notification Form

The MyMinfin online filing platform was not accessible upon release of legislation. However, the notification form's content has been published in Dutch and French, and an XML conversion tool is available in Dutch, English, and French. Below is a detailed guide on how to fill out the notification form, which is divided into four main sections:

Section I: MNE Group Information

In this section, you need to provide general information about the MNE group:

• Group Name: Enter the full legal name of the MNE group.
• Reporting Year Start and End Dates: Specify the beginning and ending dates of the reporting year.
• Address of the UPE: Provide the address of the Ultimate Parent Entity (UPE) that prepares the consolidated financial statements.
• Legal Form of the Entity: Indicate the legal form (e.g., corporation, partnership).
• Nature of the Group: Describe the nature or primary business activities of the group.

Section II: Consolidated Financial Statements

This section requires details about the consolidated financial statements of the MNE group or large Belgian domestic group:

• Consolidation Standards Used: State which accounting standards are applied (e.g., IFRS, US GAAP, BE GAAP).
• Publication of Financial Statements: Provide the online location where the consolidated financial statements are published.
• Currency Used: Specify the currency in which the consolidated financial statements are prepared.

Section III: MNE Group Structure

Here, you need to detail the ownership structure of the group:

• Ownership Details: Include information about the UPE, Intermediate Parent Entities (IPEs), and Partially Owned Parent Entities (POPEs), regardless of their location.
• GloBE Status: Determine and state the "GloBE" (Global Anti-Base Erosion) status of each entity in the structure.
• Additional Analysis: If the group has multiple IPEs or specific entities like POPEs, additional analysis is required to ensure all necessary information is included.

Section IV: Point of Contact

This section requires information about the entity that will serve as the contact point for the group:

• Contact Name: Provide the name of the contact person.
• Tax Identification Number: Enter the tax identification number of the contact entity.
• Address: Include the address of the contact entity.
• Email Address: Provide the email address for correspondence.

Sources/recommended read:

• Formulaires et tools | SPF Finances (belgium.be)
• Formulieren en tools | FOD Financiën (belgium.be)
• Action required: Mandatory Pillar Two notification in Belgium for MNEs and large domestic groups | Tax Alerts | Deloitte Belgium