On 4 November 2009, the Court of First Instance Hasselt (Rechtbank van Eerste Aanleg Hasselt) decided two joined cases (recently published) X and Z v. the Tax Administration on the moment when the level of a participation had to be determined for the levy of withholding tax on interest under both the Belgium-Germany tax treaty on income and capital of 11 April 1967 and the Belgium-Luxembourg tax treaty on income and capital of 17 September 1970 (collectively, "the Treaties" because the relevant provisions of each treaty are identical in all material aspects). Details of the cases are summarized below. (a)...