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Friday, 30 June 2023

Breaking - The new double taxation treaty between the Netherlands and Belgium



On 21 June Belgium and the Netherlands signed a new double tax treaty on income taxes. Unlike under the current treaty, the scope of this treaty will be limited to income taxes. It will therefore not (any longer) cover capital gains taxes.

This treaty replaces the treaty of 5 June 2001 as supplemented by the Protocol of 23 June 2009.  Once the assent procedures are over, it can enter into force (in all likelihood at the earliest on 1.1.2025).


Compared to the current treaty, a number of notable changes stand out.

In the coming weeks and months, you can expect more information from us on the following topics in periodic newsletters:

  • The implications for retail investors (including the ‘JTER’)
  • The Cayman tax in a Belgian-Dutch context
  • Important changes regarding withholding tax on dividends, interests and royalties
  • The Dutch taxing rights on dividends, interests and capital gains on shares upon immigration from the Netherlands to Belgium
  • The new adjusted permanent establishments concept
  • Consequences for the taxation of funds
  • Important changes for teachers (and certain academics)
  • Changes for sportsmen
  • Changes for artists
  • Generous measures in favour of cross-border workers, and other changes relevant to employees
  • Effective taxation requirement to avoid double taxation
  • OECD-compliant interpretation and mutual agreement with binding solution in case of double (non-)taxation

If you wish to receive our newsletters, register now and learn all about this new treaty.

In addition, we will keep you informed of upcoming events that will be scheduled on this topic.




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