With the law of 19 December 2023, a minimum tax rate of 15% is imposed on Multinational enterprise groups (MNE groups) and Large domestic groups.  This applies to groups with an annual turnover of at least €750 million in two or more of the four reporting years preceding the reporting year under consideration. 

 

Pillar 2 Gourp Notification and CBE Group

 
To be compliant with this new legislation, multinational enterprise groups and large national groups subject to the minimum tax under the Pillar 2 new legislation must register with the Crossroads Bank for Enterprises (CBE). 


To register with the CBE, a multinational enterprise (MNE) group or large-scale national group must notify the Belgian tax authorities using an electronic notification form and file it on MyMinfin, the Belgian tax administration's electronic platform. This notification must be submitted no later than 30 days after the start of the tax year for which the group falls under the law of 19 December 2023. However, to allow adequate time for collecting the required information, the notification period is extended to 45 days after the publication of the Royal Decree of 15 May 2024 in the Belgian Official Gazette for those who have already started or are about to start their first tax year. Please note that in the meantime the Royal Decree has been published (29 May 2024). This means that the first deadline is  13 July 2024. 


The notification must be made: 

  • where a single ultimate parent entity is established in Belgium: by that single ultimate parent entity.
  • where more than one ultimate parent entity is established in Belgium: by the ultimate parent entity designated as proxy (mandate).
  • where no ultimate parent entity and only one constituent entity is established in Belgium: by that sole constituent entity.
  • where there is no ultimate parent entity and several constituent entities are established in Belgium: by the constituent entity designated as the proxy (mandate).

 

The mandate must be given by means of a form. This form is digitally signed and is submitted at the same time as the notification form.


If the notification form contains all the necessary information, the tax authorities will register the MNE group or the large national group with the CBE. The group's business number will then be sent by e-mail to the entity that notified the group.


RSM Belgium is able to help you with regards to that obligation.


If you have any questions regarding this topic, don’t hesitate to contact our RSM Belgium | Tax team ([email protected]).