In a decision of 16 January 2007 (reported 31 May 2007), the Court of Appeal Ghent (Hof van Beroep Gent) decided in a case on the existence of a permanent establishment (PE) under the 1970 Belgium-Netherlands tax treaty on income and capital (the "treaty"). Details of the case are summarized below. (a) Facts. A Dutch distribution centre of an international group is responsible for the maintenance of central and local stock levels of spare parts, which are necessary for maintenance contracts with clients. In 1995, 1996 and 1998 the Dutch company owned a stock of goods in Belgium for the...