On 2 August and 23 November 2011, respectively, the Court of First Instance (Gerecht van Eerste Aanleg) Brussels decided two cases on the compatibility of the special tax imposed on foreign collective investment funds with the Belgium - Luxembourg Income and Capital Tax Treaty (1970) (the Treaty), as amended by the protocols of 2002 and 2009.Details of the case are summarized below. (a) The Taxpayer in both cases was a Luxembourg SICAV ("the Taxpayer") registered with the authority for Financial Services and Markets in Belgium. Due to their registration, the Taxpayers became subject to a 0.8% tax for foreign collective investment funds....