On October 23, 2025 Belgium’s tax authority published online the Circular 2025/C/68, guiding on the applicability of OECD’s 15% global minimum tax for large multinational groups. The guidance, among others, explains the administration aspects of the income inclusion rule, qualified domestic top-up tax, and undertaxed profits rule. Also, it clarifies the treatment of R&D tax credits and controlled foreign corporations.
To access the Circular, click here.