End of the tax agreement between Belgium and France for public sector cross-border workers

What changed?

France has since unilaterally terminated this agreement, so the pre-18 March 2025 tax situation applies again:

• Belgians living and working in Belgium for a French public employer are now taxed again in Belgium.

• French nationals living in France and working for a Belgian public employer are taxed in France.

• Persons with dual Belgian-French nationality are taxed in their country of residence.

What are the consequences?

The termination of the agreement has both practical and tax implications. Belgian public employers without industrial or commercial activities (such as schools, municipalities or hospitals) are no longer obliged to withhold tax from the wages of French employees with French nationality.

Workers may face double tax returns in Belgium and France.

What should you do as a cross-border worker in the public sector?

• Check your situation: Do you work for a foreign government? Check whether your employer still applies the correct tax deductions.

• Prepare your returns: You may have to declare your income in both countries.

• Avoid double taxation: Are you being taxed in both countries? Then you can start an amicable procedure in your country of residence. For this, you have three years from the first assessment.

Why this change?

The French tax authorities reinterpreted the 1964 tax treaty between Belgium and France in 2025. Although this interpretation was initially accepted through the March 2025 agreement, France has now withdrawn this agreement. The Belgian FPS Finance has issued an official press release about this and will further inform affected employers.

Are you in this situation or do you have any further questions about it? Don’t hesitate to contact us, we are happy to help!