Belgium has moved the deadline for groups to submit their GloBE Information Return (GIR) notification to 30 September 2026, providing additional time for multinational groups with consolidated revenue of EUR 750 million or more to meet their Pillar Two filing obligations under the Minimum Tax Directive (EU) 2022/2523. The extension aligns Belgium with a broader pattern of transitional relief being adopted across EU member states as groups navigate the operational complexity of first-cycle GIR compliance. Affected groups should treat this date as firm and use the remaining window to finalise their data, review their qualifying status, and confirm their notification approach with Belgian tax counsel.
What Changed and When
The Minimum Tax Directive (EU) 2022/2523 – the EU's implementation of the OECD/G20 Pillar Two framework – requires in-scope groups to file a GloBE Information Return with the competent authority of each jurisdiction where they operate or have a top entity. For fiscal year 2024, the default deadline across most jurisdictions was 30 June 2026.
Belgium has extended its GIR notification deadline to 30 September 2026. This is consistent with the approach taken by other member states: France announced an extension to 1 September 2026 (announced 8 July 2026), and Portugal confirmed that no penalties would apply for notifications filed before 30 September 2026 under Order 76/2026-XXV of 3 June 2026. The competent authority in Belgium for Pillar Two compliance purposes is FPS Finance.
Separately, on 5 January 2026 the OECD/G20 Inclusive Framework approved the so-called Side-by-Side package, introducing UPE safe harbours, simplifications for substance-based incentive treatment, and further guidance on transitional safe harbours. Commission Notice C/2026/253 (12 January 2026) confirmed that this package applies under the Directive. On 11 September 2026, the OECD released an updated GIR template covering fiscal years beginning on or after 31 December 2025; groups filing for FY2024 should confirm which template version applies to their submission with their advisers.
Who Is Affected
The Pillar Two rules apply to multinational enterprise (MNE) groups with consolidated annual revenue of EUR 750 million or more in at least two of the four fiscal years immediately preceding the tested year. Both in-bound groups (with a Belgian constituent entity) and out-bound Belgian-headed groups are within scope.
Affected parties typically include:
- Groups with a Belgian ultimate parent entity (UPE) or intermediate parent entity (IPE) designated as the filing entity;
- Belgian constituent entities that may carry a secondary or backstop filing obligation where the UPE jurisdiction has not exchanged GIR data with Belgium;
- Groups relying on transitional safe harbours (Qualified Domestic Minimum Top-up Tax, or QDMTT, safe harbours) who still have notification and documentation obligations;
- Groups affected by the Side-by-Side package, particularly those with substance-based incentive regimes or UPE-level structures that interact with the new safe harbour provisions.
Groups registered in the Banque-Carrefour des Entreprises / Kruispuntbank van Ondernemingen (BCE/KBO) with relevant cross-border structures should confirm their constituent entity map and filing obligations as part of their immediate review.
Key Dates at a Glance
| Event | Date | Notes |
|---|---|---|
| OECD Side-by-Side package approved | 5 January 2026 | Inclusive Framework; confirmed by Commission Notice C/2026/253 |
| Commission Notice C/2026/253 | 12 January 2026 | Application under Directive (EU) 2022/2523 confirmed |
| Portugal transitional relief order | 3 June 2026 | Order 76/2026-XXV; no penalties to 30 September 2026 |
| Default GIR filing deadline (most jurisdictions) | 30 June 2026 | FY2024 |
| France extension announced | 8 July 2026 | Extended to 1 September 2026 |
| Updated OECD GIR template released | 11 September 2026 | Applies to fiscal years beginning on or after 31 December 2025 |
| Belgium GIR notification deadline | 30 September 2026 | Extended from 30 June 2026; FPS Finance |
Immediate Action Items for International Groups
Given the compressed timeline, groups should prioritise the following steps before 30 September 2026:
- Confirm filing entity and jurisdiction: Identify whether the Belgian entity files as UPE, IPE, or local constituent entity, and verify whether a qualifying competent authority agreement is in place between Belgium and the UPE jurisdiction that would permit centralised GIR filing.
- Assess Side-by-Side package impact: Review whether the UPE safe harbour or substance-based incentive simplifications approved on 5 January 2026 alter your group's top-up tax computation or notification obligations for FY2024. Legal advice on the interaction with existing tax structuring arrangements in Belgium may be necessary.
- Review GIR template version: The OECD released an updated GIR on 11 September 2026 for fiscal years from 31 December 2025 onwards. For FY2024 submissions, verify with FPS Finance and your advisers which template version is required and whether transitional provisions apply.
- Document safe harbour reliance: Groups relying on transitional QDMTT safe harbours or CbCR-based safe harbours should ensure their underlying documentation – including Country-by-Country Reports and applicable corporate law records in Belgium – is in order and auditable by FPS Finance.
- Coordinate cross-border filings: Groups with constituent entities in France, Portugal, and Belgium should align filing timelines and data sets across jurisdictions to avoid inconsistencies that could trigger a tax audit or transfer pricing adjustment in any of the three jurisdictions.
If your group is working through the Belgian GIR notification or assessing exposure under the Side-by-Side package, Ferraz & Whitmore can help you map obligations, review documentation and coordinate with FPS Finance. Contact us at info@ferrazwhitmore.com or visit our contacts page to arrange a consultation.
Broader Context: Coordinated EU Transition
The extensions granted by Belgium, France, and Portugal reflect a pragmatic acknowledgement by EU member state tax authorities that first-cycle GIR compliance is operationally demanding, particularly for groups navigating the interaction between national implementation rules, OECD administrative guidance, and anti-avoidance rules embedded in domestic legislation. The Minimum Tax Directive itself leaves certain implementation details to member state discretion, and groups should not assume that the Belgian approach mirrors that of other jurisdictions without verification.
Groups with operations or holding structures in other jurisdictions undergoing comparable reforms – for example, Singapore's ongoing consultation on its Pillar Two framework (see our Singapore Finance Bill 2026 consultation alert) – should also monitor whether their GIR obligations in those jurisdictions are affected by the updated OECD template or the Side-by-Side package.
Robust tax risk management at this stage means not only meeting filing deadlines, but also stress-testing the group's GloBE computations against the risk of FPS Finance enquiries, ensuring transfer pricing documentation is consistent with GIR disclosures, and confirming that any treaty positions relied upon are supportable in light of the OECD's evolving guidance.
For groups seeking a structured review of their Belgian Pillar Two position, our tax practice in Lisbon and Belgium works with local correspondents to provide joined-up advice across jurisdictions. Reach us at info@ferrazwhitmore.com or through our contacts page.
Sources
- Irish Revenue – Pillar Two Key Dates: www.revenue.ie
- Minimum Tax Directive (EU) 2022/2523
- OECD/G20 Inclusive Framework Side-by-Side package, approved 5 January 2026
- Commission Notice C/2026/253, 12 January 2026
- Portugal Order 76/2026-XXV, 3 June 2026
- OECD Updated GIR Template, 11 September 2026
Key facts last verified: 22 September 2026.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.