Pillar 2: Registration obligations in Belgium and UK
Work on the introduction of a global minimum tax under Pillar 2 is gaining momentum. In this context, we bring to your attention new registration obligations in Belgium and the UK.
Belgian authorities have introduced an obligation to register for a minimum tax for all multinational groups (with consolidated group revenue exceeding EUR 750 million) that have an ultimate parent, parent or another member entity in Belgium, including permanent establishments. This obligation applies to taxable periods beginning on or after 1 January 2024.
The registration form contains detailed information about the group, including information from the consolidated financial statements, such as currency, period and accounting standard. A description of the ownership structure is also an important part of the form. Registration is not yet possible, but the system is expected to be available soon. The deadline for registration will generally be 45 days from the date when the registration system becomes available. The registration obligation in Belgium results from the obligation to make tax prepayments already in the first period in which the tax will be applied. More detailed information can be found here.
Practical guidance on registration requirements has also been issued by UK authorities. The registration obligation applies to any multinational group subject to the global minimum tax, with at least one entity in the UK. Registration will be compulsory even if no UK top-up tax liability arises. Unlike Belgium where registration is required already during 2024, in the UK the deadline for registration has been set at six months from the end of the first accounting period that began after 31 December 2023. For more details, click here.
The registration obligation for minimum tax under Pillar 2 is not a rule, and, e.g., the Czech Republic has not introduced any such obligation.