Executive Summary
Belgium enacted major tax and customs legislation this week, including the transposition of EU DAC9 for crypto-asset reporting, a four-month extension of the Pillar Two QDMTT filing deadline to 15 months, and the EU publication of the reformed Union Customs Code establishing a centralized EU Customs Authority. Simultaneously, a draft family tax credit reform proposes a 0.25% employer social security contribution increase and pension deductibility caps, while the mandatory mobility budget rollout faces a likely phased delay. Employers must also apply the indexed Q4 2026 social security ceiling of €12,489 immediately.
Important Updates
Belgium Adopts DAC9 and Extends Pillar Two QDMTT Filing Deadline
On 30 October 2026, Belgium enacted legislation implementing EU Directive 2023/2213 (DAC9), amending Directive 2011/16/EU on administrative cooperation. The law simultaneously amends the Belgian Pillar Two implementing legislation transposing the OECD/G20 BEPS 2.0 GloBE rules. Published in the Belgian Official Gazette, it applies to fiscal years starting on or after 31 December 2023. DAC9 introduces mandatory automatic exchange of information on crypto-asset transactions and e-money, significantly expanding reportable financial accounts. Crypto-Asset Service Providers (CASPs) and e-money institutions must collect and report detailed transaction data to Belgian tax authorities for onward exchange with EU member states, with reporting commencing 1 January 2026 and first exchange due by 31 July 2027.
The most impactful change for multinational enterprise (MNE) groups with consolidated revenue exceeding EUR 750 million is the extension of the Qualified Domestic Minimum Top-up Tax (QDMTT) filing deadline from 11 to 15 months after fiscal year-end. This aligns with flexibility granted by the EU Minimum Tax Directive (2022/2523) and provides MNEs an additional four months to finalize complex GloBE calculations, consolidate cross-jurisdictional data, and submit the QDMTT return alongside the corporate income tax return. The legislation also clarifies the QDMTT credit mechanism interaction with Belgian corporate income tax assessment, preventing double taxation. The first QDMTT return for the fiscal year ending 31 December 2024 is due by 31 March 2026. Non-compliance penalties include administrative fines up to EUR 50,000 per violation and potential criminal sanctions for deliberate evasion.
Sources: EY Tax Alert
EU Reformed Union Customs Code Published: Centralized Authority, Trust & Check Program, E-Commerce Changes
On 21 October 2026, the reformed Union Customs Code (UCC) was officially published in the EU Official Journal, marking the most significant overhaul of EU customs legislation since 2016. Driven by the EU Customs Reform Package, the reform aims to modernize customs processes, enhance risk management through data analytics, and address e-commerce, supply chain complexity, and geopolitical tensions. Key changes include the establishment of a centralized EU Customs Authority (EUCA) to coordinate risk management and audit selection across member states, replacing the fragmented national approach. A new Trust & Check Traders program replaces the Authorized Economic Operator (AEO) framework, introducing tiered benefits based on real-time data sharing and compliance history. The reform mandates electronic customs declarations for all goods movements, phasing out paper-based processes entirely by 2027.
For e-commerce, the EUR 150 low-value consignment relief is abolished; all imports are subject to VAT and customs duties regardless of value, with a simplified declaration regime for consignments up to EUR 150. The concept of ‘customs supervision’ expands to cover goods in free zones and temporary storage, requiring enhanced record-keeping. New customs valuation provisions introduce a hierarchy of methods aligned with WTO rules but with stricter documentation requirements for related-party transactions. The Belgian customs administration (FPS Finance) has issued implementation guidelines aligning national procedures. The reformed UCC enters into force 10 November 2026, with most substantive provisions applying from 1 January 2027. The EUCA becomes operational by 1 January 2028, Trust & Check applications accepted from 1 July 2027, and e-commerce relief abolition applies from 1 January 2027. Businesses should immediately conduct gap analyses, update IT systems for EDI with the EUCA platform, and prepare Trust & Check applications.
Sources: EY Tax Alert
Draft Family Tax Credit Law Proposes Employer Contribution Hike and Pension Deductibility Cap
On 3 November 2026, the Council of Ministers approved a preliminary draft law reforming the family tax credit (familiekrediet) system, aiming to simplify child-related tax benefits and increase support for low- and middle-income families. The draft merges the existing refundable tax credit, increased dependent spouse allowance, and regional child allowances into a single monthly payment administered by the FPS Finance, effective 1 January 2027. The new universal credit would provide a base amount of €185/month per child under 18, phasing out for household net taxable income above €65,000 (taper rate 5%). It eliminates the current tax credit for dependent spouses (€1,800/year), replacing it with a targeted allowance for single-earner households with children.
Critically, the estimated €2.3 billion annual cost would be financed through a 0.25 percentage point increase in the employer social security contribution (from 25.00% to 25.25%) and a reduction in the deductibility of employer-paid pension contributions from 100% to 95% for contributions exceeding €5,000 per employee annually. The VBO/FEB and other employer federations issued a joint statement expressing “extreme criticism” regarding the funding mechanism and administrative burden. The employer contribution hike directly increases labor costs for all Belgian employers by an estimated €450 million annually, affecting multinational enterprises with significant Belgian workforces. The pension deductibility cap impacts executives and high earners, reducing tax efficiency of supplementary pension plans. Payroll departments must implement new withholding logic for the universal child benefit, coordinate with regional family allowance funds (Famiris, KidsLife, Infino), and adjust year-end tax certificate (281.10/281.20) reporting.
The draft law enters parliamentary debate in November 2026, targeting enactment before 31 December 2026 for 1 January 2027 effect. Employers must update payroll systems by December 2026 to apply the increased contribution rate and new pension deductibility rules. The FPS Finance will issue a circular detailing the monthly child benefit calculation and data exchange protocol by 15 December 2026. Failure to withhold the additional 0.25% employer contribution attracts a 15% surcharge plus interest. Companies are urged to model the cost impact on 2027 budgets immediately and engage in the parliamentary consultation process via sector federations.
Sources: VBO/FEB Position Paper
Secondary Regulatory & Regional Updates
- Belgian Mobility Budget Mandatory Rollout Delayed to 2027-2028 Phased Approach: The Federation of Belgian Enterprises (VBO/FEB) stated on 21 October 2026 that the planned mandatory rollout of the federal mobility budget for all employers with 20+ employees by 1 January 2027 is technically and administratively unachievable. The core tax advantage — exemption from social security contributions and personal income tax up to the value of the foregone company car (capped at €20,000 annually) — remains intact. However, the mandatory offer requirement is likely postponed by at least six months. VBO/FEB proposes a phased approach: voluntary adoption in 2027, mandatory for large enterprises (>250 employees) from 1 July 2027, and for SMEs (20-249 employees) from 1 January 2028. The federal government acknowledged concerns and indicated a Royal Decree amending the timeline will be published before year-end 2026. Employers should not dismantle existing car fleet contracts, prepare internal mobility budget policies, conduct employee surveys, and engage sectoral social partners for collective bargaining agreements. The digital registration platform (Mobibudget.be) is committed for launch by 31 March 2027. Non-compliance may result in loss of tax exemption for company cars and administrative fines of €400 per employee per quarter. VBO/FEB Position Paper
- Q4 2026 Social Security Contribution Ceiling Indexed to €12,489: On 27 October 2026, the Belgian National Social Security Office (ONSS/RSZ) published official contribution rates and ceilings for Q4 2026 (October–December) via Circular 2026/Q4, effective retroactively from 1 October 2026. The overall employer contribution rate remains stable at 25.00% for most private-sector employers, employee share at 13.07%. The quarterly ceiling for social security contributions has been indexed to €12,489.00 (up from €12,186.00 in Q3 2026), reflecting the health index adjustment. Special reductions for target groups continue unchanged; structural reduction for low-wage earners sees marginal bracket threshold increases. The solidarity surcharge for high-income earners (above €6,200 monthly) remains at 2.5% on the excess. All employers must apply the new ceiling immediately for payroll processing via the monthly DmfA declaration by the last day of the following month. Late or incorrect application may result in administrative fines of 10% of omitted contributions plus interest at 7% per annum. ONSS/RSZ announced a targeted audit campaign in Q1 2027 focusing on year-end bonus calculations and ceiling application. Companies advised to conduct pre-closing payroll review by mid-December 2026. VBO/FEB News
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.