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Wednesday, 10 November 2021

Breaking news : Belgium and France signed a new Double Tax Convention

On 9 November 2021, after long discussions and negotiations, France and Belgium signed a new Double Tax Convention (‘DTC’).

Once the ratification process will be completed in both countries, this new DTC will enter into force (most probably on 1st January 2023 at the earliest).

Unlike the DTC currently in force, which is more than half a century old, the new DTC will be more in line with the OECD Model Convention.

In the following weeks, we will publish specific newsflashes on novelties brought by this new DTC and which may significantly impact the tax situation of Multinational Enterprises on various topics. We will amongst others discuss the changes for cross-border employment and international shipping and air transport and the introduction of new set of rules, such as the special rules for real estate development companies.

Furthermore, our French Desk will help us offer a broader coverage of the study of this new DTC. 


Ahmed El Jilali - Senior Associate (

Tiberghien’s international tax team will continue to monitor these and other tax developments relevant for Belgium / Luxembourg based multinational enterprises. Our editorial board consists of:

Koen Morbée (International and EU corporate tax,;

Michiel Boeren (International and EU corporate tax,;

Ahmed El Jilali (International and EU corporate tax,

Katrien Bollen (HR tax and global mobility,;

Ben Plessers (Transfer Pricing and Valuations,;

Gert Vranckx (VAT, customs, excises and other indirect taxes,;

Rik Smet (International and EU corporate tax,


In case you have further questions on this publication or want to discuss a tax query, please do not hesitate to contact the author(s) or one of the members of the editorial board.


This newsflash is for information purposes only and cannot be relied upon as legal advice.

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