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Belgium: Double tax treaty with Netherlands now subject to MLI

10 December 2021

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Tax Alerts, Legislation & Policy, Na...

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Belgium, Netherlands

Executive summaryOn 25 November 2021, the Belgian and Dutch tax authorities notified the Belgium-Netherlands double tax treaty as a covered tax agreement under the Multilateral Instrument (MLI).The pending treaty negotiations between Belgium and the Netherlands were the reason for not notifying the Belgium-Netherlands treaty as a covered tax treaty before. However, following a certain delay in this negotiation process, both countries decided to now implement the tax treaty-related Base Erosion and Profit Shifting (BEPS) measures into the Belgium-Netherlands double tax treaty. However, the negotiations on the other treaty provisions will continue.Both countries have opted to apply a shorter period than...