Belgium and Liechtenstein sign double taxation treaty

The treaty follows the intelligence-sharing agreement the two countries already concluded in 2009. Although the treaty has since been signed, it will not enter into force until it is ratified by the parliaments of both countries. Effective application is therefore expected only within a few years.

Alignment with international standards

The treaty is based on the OECD model treaty and takes into account the latest European measures against tax avoidance and tax evasion.

Exemption from withholding taxes in specific situations

Under certain conditions, the Double Tax Treaty provides for an exemption from withholding tax on:

• intra-group dividends;

• interest on intercompany loans;

• royalties, when the recipient of the income qualifies as the beneficial owner.

Increased legal certainty for foundations, trusts and funds

The Protocol to the Convention also contains specific provisions for, among others:

• funds;

• foundations;

• trusts;

• pension vehicles.

The additional guidelines around Liechtenstein foundations and trusts provide greater clarity and legal certainty.

Questions?

While these provisions are among the most prominent changes, the new Double Tax Treaty contains numerous other provisions.

Our specialists closely monitor international tax developments and would be happy to assist you in analyzing the potential implications for your transactions in or with Liechtenstein. Please feel free to contact us by filling out the contact form below.