A Royal Decree of 3 July 2005 to amend the Royal Decree to the Belgian Income Tax Code (RD-ITC) with respect to withholding taxes on interest was published in the Official Gazette of 14 July 2005. The Decree applies with retroactive effect from 5 June 2003.

Art. 107(2)(5)(a) of the RD-ITC provides for an exemption from withholding tax with respect to interest on deb…