Belgium Issues Wide-Ranging Global Minimum Tax Guidance

The Belgian tax authority issued guidance detailing how it will implement and administer the global minimum tax.

Circular 2025/C/68, issued Oct. 23, outlines how the country will apply the three major taxes that make up the law: the income inclusion rule, qualified domestic top-up tax, and the undertaxed profits rule.

The circular also details the impact of research and development credits, along with rules regarding controlled foreign corporations.

• The global minimum tax, also known as Pillar Two of the OECD’s global tax deal, seeks to set a 15% minimum tax rate on large multinationals. It is being rolled ...