International Tax 2026 Comparisons

The main sources of international tax law in Belgium are:

• constitutional principles (eg, the principle of legality);
• EU law (eg, the Parent-Subsidiary Directive, the Interest and Royalties Directive and the Anti-Tax Avoidance Directives);
• domestic legislation (eg, the Income Tax Code (CIR 92));
• administrative guidance (eg, circular letters);
• case law; and
• tax treaties.

Belgium has established a comprehensive network of more than 150 bilateral tax treaties.

Belgium adheres to the principle of treaty supremacy, pursuant to which duly ratified and officially published international agreements override conflicting domestic legislation. This hierarchical principle is equally applicable in tax matters.

Belgium, as founding member state of the OECD, predominantly aligns its treaty policy with the OECD Model Tax Convention. The OECD Model serves both as a reference point in treaty negotiations and as a tool for interpreting tax treaties. The Belgium Model Tax Convention (last updated in 2010) is therefore widely inspired by the OECD Model. The protocol to the Belgian Model Tax Convention explicitly confirms this by stipulating that the OECD Commentaries should be followed when interpreting the relevant tax treaty.

While Belgian tax treaties predominantly follow the OECD Model, the UN Model Convention also has a notable influence, particularly in Belgian tax treaties concluded with developing countries. Such treaties most frequently include the construction permanent establishment provision, the service permanent establishment provision and the withholding tax on royalties provision, as provided in the UN Model.

Belgium is a signatory to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Belgium signed the MLI on 7 June 2017 and deposited the instrument of ratification with the OECD on 26 June 2019. The MLI entered into force for Belgium on 1 October 2019. The MLI provisions entered into effect for withholding taxes levied as from 1 January 2020, provided that the MLI had also entered into force in the contracting state. With respect to all other taxes (including the corporate income tax), the MLI entered into effect for taxable periods beginning on or after 1 April 2020.

Belgium designated 99 bilateral tax treaties as Covered Tax Agreements (CTAs) at the time of signing the MLI. The number of tax treaties that are actually modified by the MLI is, however, lower, as the MLI only applies if both contracting states have ratified it and have designated the tax treaty as a CTA.

In Belgium, the general principle of territorial taxation distinguishes between residents and non-residents. Residents, whether individuals or companies, are taxed on their worldwide income, meaning income from both Belgian and foreign sources, while non-residents are taxed only on Belgian-source income (eg, immovable property income or profits from a Belgian permanent establishment).

In Belgium, an individual is considered a Belgian tax resident if they have established either their domicile in Belgium or, if no domicile exists, the seat of their wealth in Belgium. Tax residency is determined based on factual circumstances, meaning nationality is irrelevant.

Tax Domicile

The primary criterion for tax residency is the individual’s tax domicile, defined as the place where a person effectively and habitually lives with a certain degree of stability and continuity. This concept differs from the civil law notion of domicile, as Belgian tax law emphasises actual circumstances rather than intention.

Belgian law provides a rebuttable presumption: individuals registered in the Belgian National Register of Natural Persons are presumed to have their tax domicile in Belgium, unless they can provide sufficient evidence to the contrary. For married couples or legally cohabiting partners, tax residency is irrebuttably presumed to be at the location of their shared household.

In determining the tax domicile, authorities consider factors such as:

• the place where the individual effectively and permanently resides;
• where the individual lives and works;
• the location of the family household; and
• where the individual maintains their vital personal and social relations.

If these factors point to different jurisdictions, the location of the individual’s family and personal ties is generally a more decisive factor than, for example, temporary work or physical presence.

Seat of Wealth

If an individual has no tax domicile in Belgium, they may still be considered a Belgian tax resident if Belgium is the place from which they manage their wealth or business affairs. This refers to where the person administers assets, supervises wealth management, or maintains the centre of their economic and professional interests. The physical location of assets is not decisive; the key factor is where the wealth is effectively managed.

Individuals who are Belgian tax residents are generally subject to personal income tax on their worldwide income. This means that income earned both in Belgium and abroad is, in principle, taxable regardless of where it is paid or received.

However, in order to mitigate double taxation, worldwide income may not be fully taxed in Belgium due to (i) the application of a double tax treaty or (ii) a unilateral tax reduction.

If a tax treaty applies, certain foreign-sourced income (eg, income from immovable property) could be exempt from taxation in Belgium. It should be noted that under the “exemption with progression” method, the exempt income could still be considered when determining the applicable progressive tax rate on the taxpayer’s income taxable in Belgium, which can increase the effective tax rate.

Second, if no tax treaty applies, Belgium may grant a unilateral tax reduction to partially relieve double taxation. This relief typically applies to specific types of foreign income and is generally limited to a portion of the Belgian tax that would otherwise apply, ensuring partial mitigation of double taxation even in the absence of a treaty.

Non-resident individuals in Belgium are taxed on income that is earned or sourced within Belgium. The Belgian tax system relies on the principle of territoriality: only income with a sufficient connection to Belgium can be taxed. That connection may arise from the location of a property, the place where the activity is carried out, or the allocation of costs for a particular form of remuneration. Such income includes, among others, remunerations for employment exercised in Belgium, profits from business or professional activities carried out in Belgium through a Belgian establishment, rental income from Belgian property and certain dividends, interest, and royalties. The specific tax treatment varies depending on the type of income.

In Belgium, a legal entity is generally considered a Belgian tax resident if it meets three cumulative criteria:

• first, the entity must have legal personality under Belgian law or be a foreign entity established in a form comparable to a Belgian company with legal personality;
• second, the entity must carry out business or profit-making activities; and
• third, the entity must have its principal place of management or its effective seat in Belgium (“real seat doctrine”).

A company whose statutory seat is located in Belgium is presumed to have its effective management in Belgium, unless it can demonstrate that its management is located abroad and that it is considered tax resident in another jurisdiction under its domestic law or the applicable tax treaty.

Under the “real seat” doctrine, companies could be subject to Belgian corporate taxation even if they are governed by the corporate law of another country.

The concept of permanent establishment (PE) is defined in domestic law through the notion of a “Belgian establishment”. This definition is clearly inspired by Article 5 of the OECD Model Tax Convention, as it uses the same core concept of a “fixed place of business” through which the activities of a foreign enterprise are wholly or partly carried on, and it includes a similar non-exhaustive list of examples.

However, the Belgian domestic definition is broader than the OECD Model definition in several respects. Most notably, Belgium applies a much lower threshold for construction sites, as a construction project may constitute a Belgian establishment if it lasts more than 30 days, whereas the OECD Model uses a 12-month threshold. In addition, Belgium provides for a wider dependent agent rule: a Belgian establishment may exist even if the intermediary does not have authority to conclude contracts, which goes beyond the standard OECD approach.

Belgium also includes an explicit service PE rule, whereby the provision of services in Belgium through individuals present for more than 30 days within a 12-month period (without a fixed place) may create a Belgian establishment. The concept of a service PE is not part of the standard OECD Model.

In its tax treaties, Belgium generally follows the OECD Model definition of a PE. The Belgian Model Tax Convention largely mirrors the structure and wording of Article 5 OECD Model. However, the Belgian Model Convention (2010) reflects the pre-BEPS version of Article 5 and does not fully incorporate certain BEPS Action 7 developments, such as the explicit anti-fragmentation rule introduced in the updated OECD Model.

Belgian Tax Residents

Belgian resident individuals are taxed on their worldwide income, including income derived from Belgian and foreign immovable property.

Belgian immovable property

• For private rental (unfurnished, private use by tenant), the taxable income is based on the indexed cadastral income (KI), increased by 40%, and taxed at progressive personal income tax rates.
• For professional rental (business use by tenant), the taxable income is based on the actual rental income received, reduced by either actual expenses or a lump-sum deduction (capped at 40%), and taxed at progressive rates.
• For furnished rental, the rental income is split between immovable and movable income. In the absence of contractual allocation, 40% is deemed movable income, taxed separately at 30% after a 50% lump-sum cost deduction.

Foreign immovable property

Since assessment year 2022, foreign real estate owned by Belgian residents is assigned a surrogate cadastral income, ensuring comparable treatment to Belgian property.

• Where a double tax treaty applies, foreign immovable income is generally exempt in Belgium with progression.
• In the absence of a treaty, such income is typically taxable in Belgium at half the normal personal income tax rate (Article 155, CIR 92).

Non-Residents

Non-resident individuals are taxed only on immovable property income sourced in Belgium.

The taxable base is determined in the same manner as for residents.

• Private rental: indexed cadastral income plus 40%.
• Professional rental: actual rent less deductible expenses.

Companies

For companies (resident or non-resident), immovable income is generally included under business profits and taxed under corporate income tax rules.

Companies

Companies that are tax resident in Belgium are subject to corporate income tax on their worldwide income. The standard corporate income tax rate is 25%.

Small companies within the meaning of the Belgian Companies and Associations Code may benefit from a reduced rate of 20% on the first EUR100,000 of taxable income, provided certain conditions are met, including a minimum annual remuneration to at least one director.

Non-resident companies are only subject to corporate income tax on Belgian-source income attributable to a Belgian establishment.

Individuals

Individuals carrying out business or professional activities in Belgium (eg, self-employed persons) are subject to personal income tax on their net professional income.

Personal income tax is levied at progressive rates, ranging from 25% to 50%. In addition, a municipal surcharge applies to the federal tax due.

Non-resident individuals are taxed in Belgium on professional income derived from activities carried out in Belgium or from prior activities performed in Belgium.

Passive income (eg, dividends, interest and royalty income) is typically subject to withholding tax at source. The taxation depends on the type of income and the recipient of the income.

For Belgian resident individuals, passive income (Belgian or foreign-sourced) is generally subject to a withholding tax of 30%. Exemptions and reduced rates could be applicable (eg, VVPR-bis, liquidation reserves). The withholding tax is final, which means that the income should not be declared in the income tax return.

For Belgian resident companies, passive income (Belgian or foreign-sourced) is included in their taxable profits and subject to the standard corporate income tax rate. However, dividends may benefit from the Dividends Received Deduction (DRD) regime, under which qualifying dividends are fully exempt if certain conditions are met, including a minimum participation threshold, a minimum holding period of one year, and a subject-to-tax requirement.

Non-residents are taxed only on Belgian-source passive income. The income is subject to a 30% withholding tax rate, but an exemption or reduced rate could apply under an applicable tax treaty or EU directive (eg, the Parent-Subsidiary Directive or the Interest and Royalties Directive).

Personal income tax

Until 2026, Belgium did not impose a general capital gains tax on shares or other financial assets. As a rule, such capital gains were tax exempt, provided they were realised within the scope of the normal management of private wealth. Capital gains could, however, be taxed if they were realised in the context of a professional activity (and thus treated as professional income) or if they resulted from abnormal management, in which case a separate taxation at 33% (plus municipal surcharges) applied.

Belgium is currently in the process of introducing a general capital gains tax on financial assets as from 1 January 2026. While the legislation still needs to be formally adopted and may still be amended, it is expected that a 10% capital gains tax will apply to capital gains realised on the transfer for consideration of financial assets (including shares, crypto, liquidities and certain insurance contracts). The capital gains tax would only apply to gains realised within the scope of normal management of private wealth. Under the draft proposals, the regime would only target the increase in value accrued as from 2026, meaning that historical capital gains would remain exempt through a step-up mechanism at the end of 2025. Specific rules would also apply to (i) shareholders holding a substantial participation (ie, more than 20%), including a threshold exemption and progressive rates for higher capital gains and (ii) internal capital gains (33%).

With respect to real estate located in Belgium, capital gains are taxable depending on the type of property and the holding period. Capital gains on buildings are, in principle, taxed at 16.5% if the property is sold within five years of acquisition. Capital gains on land are taxed at 33% if sold within five years and at 16.5% if sold between the fifth and eighth year. After these holding periods, capital gains on real estate are generally exempt.

Corporate Income Tax

Capital gains are taxed as profits of the company and therefore subject to the general corporate income tax rate. Capital gains on shares should be exempt from taxation if the three conditions of the participation exemption (“dividend received deduction”) are cumulatively met.

• Minimum participation requirement: the company must hold either at least 10% of the share capital of the subsidiary, or a participation with an acquisition value of at least EUR2.5 million (in which case the shares must be qualified as “financial fixed assets”).
• Minimum holding requirement: the shares must be held in full ownership for an uninterrupted period of at least one year.
• Subject-to-tax requirement: the subsidiary whose shares are sold must be subject to a normal corporate income tax regime. This means that it may not be established in a tax haven, nor benefit from a substantially more favourable tax regime than the ordinary tax regime. In other words, the subsidiary must be effectively subject to a tax comparable to Belgian corporate income tax.

In Belgium, employment income is subject to personal income tax at progressive rates ranging from 25% to 50% (increased with municipal surcharges and social security levies). Employment income is broadly defined and includes not only base salary, but also bonuses, benefits in kind, etc.

Belgium also provides a specific expatriate tax regime for inbound employees and qualifying researchers recruited abroad or seconded to Belgium. Under this regime, and subject to meeting several conditions – including a minimum remuneration requirement for employees or relevant qualifications for researchers ‒ the employer may grant a tax-free allowance of up to 35% of the employee’s gross remuneration as a lump-sum reimbursement of expenses. In addition, certain specific costs (eg, moving expenses, school fees for minor children, home set-up costs) can be reimbursed tax-free in addition to the 35% lump sum allowance. The regime applies for a maximum period of five years, which can be extended once by three additional years.

Belgium does not have a specific tax regime for remote working. Belgian residents are taxed on their worldwide income in Belgium; however, as a general rule, under tax treaties, employment income is taxable in the state where the work is physically performed (the “work state”). An important exception is the so-called 183-day rule which may shift taxing rights to the residence state. More specifically, this applies if the following conditions are cumulatively met:

• the presence of the employee in the work state does not exceed 183 days;
• the remuneration is paid by a non-resident employer; and
• the remuneration is not borne by a permanent establishment in the work state.

There is no applicable information in this jurisdiction.

There is no applicable information in this jurisdiction.

There is no applicable information in this jurisdiction.

Belgium implemented the Pillar Two global minimum tax via the Law of 19 December 2023, which entered into force on 31 December 2023. Subsequent amendments have been made to align the legislation with the latest OECD updates and commentaries. 

The Belgian legislation aligns closely with the OECD framework and remains fully compliant with the EU Pillar Two Directive. Furthermore, specific procedural provisions have been introduced to extend the existing tax prepayment regime to the Pillar Two top-up taxes (QDMTT, IIR and UTPR), mirroring the rules currently applicable to corporate income tax.

The Belgian government has announced plans for a digital tax, though it intends to prioritise a harmonised EU framework. In the absence of a timely EU initiative, Belgium is prepared to implement a unilateral legal framework in 2027.

Tax evasion (fraud) and tax avoidance are not defined under Belgian law.

Tax evasion generally refers to an infraction of tax law committed with the aim of escaping or reducing taxation. It combines a material breach of the tax norm and a deliberate intention to avoid taxation. Tax evasion may lead to criminal prosecution. Tax avoidance, by contrast, involves legally structuring transactions to reduce tax liability. However, under the Belgian general anti-abuse rule (GAAR) (Article 344, CIR 92), arrangements that are artificial and aimed primarily at obtaining a tax advantage contrary to the purpose of the law are considered “abusive”.

Belgium has implemented a GAAR, as well as specific anti-abuse rules (SAARs) in order to combat tax abuse. The Belgian GAAR requires an objective element – wholly artificial arrangements aimed solely at obtaining a tax advantage without any genuine economic objective – and a subjective element – acting contrary to the purpose of the tax provision(s). The GAAR allows the Belgian tax authorities to disregard legal acts that are primarily tax-driven and contrary to the purpose of the law, unless the taxpayer demonstrates valid non-tax reasons.

In cross-border contexts, Belgium also relies on certain SAARs, such as transfer pricing rules (based on the arm’s length principle), Controlled Foreign Company (CFC) rules, Cayman tax rules (CFC rules for individuals), hybrid mismatch rules, interest limitation rules, and a specific anti-avoidance rule relating to the dividend received deduction.

Belgium also combats tax evasion and aggressive avoidance through the exchange of information with other jurisdictions (see 8. Mutual Agreement Procedures and Arbitration).

Belgium applies both the EU list of non-cooperative jurisdictions for tax purposes (the “EU blacklist”) and a domestic tax haven list. Transactions with entities in listed jurisdictions are subject to reporting obligations, stricter deductibility conditions, the application of CFC rules (and Cayman tax rules), denial of tax benefits, and enhanced scrutiny by tax authorities. The overall objective is to discourage profit shifting and artificial arrangements involving low-tax or non-cooperative jurisdictions.

Belgium has implemented an extensive set of reporting obligations to combat tax evasion (fraud) and aggressive tax avoidance. Key measures include DAC6 mandatory disclosure rules requiring intermediaries and taxpayers to report certain cross-border arrangements, as well as Country-by-Country Reporting and transfer pricing documentation for multinational groups. Financial institutions must report foreign account information under the Common Reporting Standards (CRS) and the Foreign Account Tax Compliance Act (FATCA), enabling the automatic exchange of data with other jurisdictions. Belgian entities must also register their ultimate beneficial owners (UBO) in the UBO register to enhance ownership transparency. In addition, companies must report payments to tax havens that exceed statutory thresholds, while AML legislation imposes obligations to report suspicious transactions. Together, these transparency mechanisms strengthen the detection of offshore income, artificial structures and profit-shifting arrangements.

Belgian tax authorities have broad investigative powers, including access to accounting and banking information, third-party data requests, on-site audits, unannounced business visits, and ‒ subject to judicial authorisation ‒ tax searches or raids (fiscal perquisitions). These tools are complemented by extended assessment periods and criminal prosecution mechanisms in cases of fraud.

Legal Framework

Belgium applies a dual sanctioning system consisting of the following.

• Administrative tax penalties governed by the CIR 92 , the VAT Code, and regional tax codes (eg, Vlaamse Codex Fiscaliteit – VCF). These penalties include tax increases, fixed administrative fines and specific sanctions relating to international obligations (eg, transfer pricing documentation or DAC6 reporting).
• Criminal tax penalties governed by the fiscal criminal provisions in the CIR 92 and the VAT Code when there is fraudulent intent.

These frameworks operate subject to core principles such as the legality principle, the motivation requirement, fundamental rights protections (eg, right to a fair trial) and the non bis in idem rule.

Competent Authorities

Competent authorities include:

• the Federal Public Service Finance (FOD Financiën) for administrative sanctions.
• regional tax administrations for regional taxes;
• the Public Prosecutor for criminal prosecutions; and
• correctional courts for the imposition of criminal penalties

Additionally, the tax administration co-operates with foreign authorities via EU directives (DAC), OECD conventions, and bilateral agreements.

Tax fraud and tax evasion can lead to a range of criminal penalties. For general fiscal fraud, the law provides for imprisonment ranging from eight days to two years, as well as criminal fines between EUR250 and EUR500 (EUR500 to EUR1 million for legal persons) before the application of surcharges.  These sanctions apply only where the authorities can prove fraudulent intent or an intent to cause harm.

When the fraud is considered “serious” (whether organised or not) ‒ for example in cases involving organised schemes, falsified documentation, or large‑scale evasion ‒ the penalties become more severe and may include imprisonment of up to five years.

In addition, fiscal forgery, such as the use of false accounting records or fraudulent documents, is a separate offence punishable by one month to five years of imprisonment and substantial criminal fines, and it requires a demonstrated specific fraudulent intent.

Finally, since 2024, any form of tax fraud, even non‑serious cases, may qualify as a predicate offence for money laundering, which can result in 15 days to five years of imprisonment, large financial penalties, and the mandatory confiscation of the proceeds of the offence.

Under the Belgian una via framework, serious tax fraud must in principle be reported by the tax administration to the Public Prosecutor. The system is designed to prevent prohibited double punishment while ensuring co-ordinated enforcement. Following such a report, structured consultation takes place between the tax administration, the Public Prosecutor, and investigative services. The prosecutor generally indicates within three months whether the case will proceed primarily through criminal prosecution or remain within the administrative framework.

If criminal proceedings are initiated, administrative penalty proceedings are normally suspended in order to avoid double sanctioning. However, the establishment and recovery of the tax debt may continue, since the tax due is not considered as a criminal sanction. In the criminal proceedings, the tax administration may introduce a self-standing civil claim (action civile) to recover the unpaid tax, surcharges, and interest, enabling the criminal court to rule on both the criminal liability and the civil tax claim.

Although administrative and criminal tracks may, in certain circumstances, coexist, they must form a sufficiently co-ordinated and coherent overall response, in line with the non bis in idem principle. Any cumulative sanctions must pursue complementary aims, be closely connected in substance and time, and remain proportionate. Where both tracks are engaged, the criminal court must take prior administrative penalties into account to prevent excessive overall punishment.

EU law, multilateral instruments and bilateral (tax) treaties form the basis of administrative co-operation in tax matters in Belgium.

Being an EU member state, Belgium has implemented the EU Directive on Administrative Cooperation (DAC), which establishes a harmonised framework to ensure administrative co-operation between EU tax authorities. The scope of the DAC has already been expanded several times covering, among others, the exchange of information relating to potentially tax-harmful cross-border arrangements (DAC6) and crypto-assets (DAC8). Belgium has also implemented both the CRS (as provided under DAC2) and the FATCA regulations.

Belgium is also a signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, which is considered the most comprehensive multilateral instrument for administrative co-operation, including in particular the exchange of information.

In addition to the general multilateral instruments, Belgium enhances administrative co-operation through more specific instruments such as the Benelux Agreement on Cooperation between Administrative and Judicial Authorities. The latter agreement enables the exchange of information relating to customs, excise and consumption taxes between the Benelux states. Belgium has also entered into several co-operation agreements

Moreover, Belgian bilateral tax treaties generally include an exchange of information provision based on the OECD Model (Article 26). This provision provides that the competent authorities shall exchange any information that is foreseeably relevant for the application of the treaty or for the enforcement of domestic tax laws, as long as it does not conflict with the tax treaty (Article 8.2).

Belgium has also concluded Tax Information Exchange Agreements (TIEAs) with countries with which it has no tax treaty (generally low or no tax jurisdictions).

The exchange of information under tax treaties can be “spontaneous”, “automatic” or “on-request”, depending on the text of the tax treaty (and protocols to the tax treaty). The competent authorities are responsible for exchanging information and must keep all information received strictly confidential.

Belgium participates in the OECD’s International Compliance Assurance Programme (ICAP), which enables MNEs and tax administrations to collaborate in a co-operative risk‑assessment process.

A new legal framework for joint tax audits ‒ as introduced under DAC7 ‒ has also been implemented in Belgian domestic law. It creates a legal basis for co-ordinated tax audits involving revenue authorities from two or more member states.

Belgium has a mutual agreement procedure (MAP) programme, which is regulated by (i) a special provision included in each Belgian tax treaty (generally Article 25) and (ii) Convention No 90/436/EEC on the elimination of double taxation in connection with the adjustment of profits of associated enterprises (the “EU Arbitration Convention”). The latter procedure only applies to transfer pricing disputes between associated enterprises that are established in an EU member state.

The MAP included in tax treaties allows taxpayers to resolve incorrect applications of the treaty. Certain older tax treaties require, for the MAP to apply, that measures taken by Belgium or the other contracting state have resulted, or will result, in double taxation contrary to the tax treaty. Double taxation is also a prerequisite for the MAP to apply under the EU Arbitration Convention.

With regard to the MAP provided in tax treaties, the request for a MAP should be filed within the limit provided in the relevant tax treaty. Each tax treaty specifies its own time limit for the MAP application. The MAP request under the EU Arbitration Convention must be filed within three years from the first notification of the action which results or is likely to result in double taxation.

Mandatory binding arbitration is not generally included in all Belgian tax treaties – even though a mandatory arbitration clause is included in the Belgian Model Tax Convention. Where included, the mandatory arbitration clause obliges the competent authorities (through an independent arbiter) to reach a binding decision when MAP negotiations fail. Belgium has also opted into the arbitration procedure (“final offer approach”) under the MLI. As a result, an arbitration clause has been included in nearly 20 covered tax agreements.

The EU Arbitration Convention provides for an arbitration resolution mechanism. If the competent authorities concerned fail to reach an agreement that eliminates double taxation, they shall set up an independent advisory commission charged with delivering its opinion on the elimination of the double taxation in question. Such opinion is binding for the competent authorities.

Belgium has an advance pricing agreement (APA) programme. It provides taxpayers with advance certainty on transfer pricing matters to avoid future disputes with the tax authorities.

Unilateral APAs are issued by the Service for Advance Decisions (the “Ruling Commission”), which is an autonomous section of the tax authorities. APAs focus on the arm’s length character of intercompany prices based on functions, risks and assets used.

Bilateral or multilateral APAs are handled by the International Relations Department of the tax authorities, which co-ordinates the APA requests with the other relevant jurisdictions. The legal base for the application of bilateral and multilateral APAs is (generally) Article 25 of Belgium’s tax treaties.

In order to obtain tax certainty in relation to international tax matters, taxpayers can obtain an advance tax ruling from the Ruling Commission. The scope of advance tax rulings is very broad, covering a wide range of federal tax matters (eg, qualification of income, restructurings). Such rulings are binding decisions on the tax authorities and are generally valid for a maximum period of five years.