What Is Tax on Capital for the Purposes of a Tax Treaty? An Analysis of Two Recent Belgian Supreme Court Decisions on the Belgian Net Asset Tax
Journal
Belgium; Luxembourg; Netherlands
Bulletin for International Taxation 2022 (Volume 76), No. 8
This article discusses two decisions of the Belgian Supreme Court on the compatibility of the Belgian net asset tax with the Belgium-Luxembourg Income and Capital Tax Treaty (1970) and the Belgium-Netherlands Income and Capital Tax Treaty (2001), which raise questions regarding “tax on capital”, “taxes covered” and treaty interpretation.