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International agreements

The international aspect of taxes, and more specifically direct taxes, has become increasingly important in recent decades. Here you will find the most important texts on the subject.

International agreements

  • Agreements for the avoidance of double taxation

    Here you can find:

    • double taxation conventions already in force.
    • recently signed conventions that have yet to be ratified.
    • useful texts: parliamentary documents and administrative circulars relating to the conventions.
       

    A. AGREEMENTS

    B. BELGIAN STANDARD MODEL

    C. OECD MODEL

    D. CALL CENTRE

    The GWO (Grensoverschrijdend Werken en Ondernemen – cross-border work and enterprise) team in Heerlen (the Netherlands) is available to answer your questions on the application of the double tax conventions concluded by Belgium with the Netherlands and Germany.

    Tel.:

    The GWO can be contacted from 9 a.m. to 4 p.m. on working days.

    The general contact centre is available to answer all your tax questions and all your questions on the application of all double taxation conventions concluded by Belgium.

    Tel.: +32 257 257 57 (standard rate)

    Email: via our contact form

  • Exchange of information

    Here you can find the international texts that facilitate cooperation and assistance between Belgian and foreign tax administrations.

    Exchange of information

    As part of the tax transparency that the international community has supported in recent years, Belgium remains committed, among other things, to transposing into our legislation the obligation to declare cryptographic assets. With the joint declaration " COLLECTIVE COMMITMENT TO IMPLEMENT THE CRYPTO-ASSET REPORTING FRAMEWORK (PDF, 88.3 KB) ", 48 jurisdictions confirm their commitment to participate in the new international standard on the automatic exchange of information for crypto-assets and thus pursue tax transparency and compliance.

  • European legislation

    Here you can find European legislation (directives, regulations, etc.) and other useful information on the international aspect of direct taxation.

    European legislation

  • Transfer pricing

    OECD (2010), Transfer Pricing Guidelines for Multinational Businesses and Tax Administrations 2010, OECD Publishing

  • International Compliance Assurance Programme (ICAP)

    The International Compliance Assurance Programme (ICAP) is a voluntary programme facilitating multilateral exchanges between multinational companies and tax administrations to enhance tax certainty and prevent disputes. The Belgian tax administration is an active participant in this program.

    The ICAP programme:

    • focuses on a multilateral risk analysis of international and cross-border risks. Within this framework, multinational groups work with the respective tax administrations, using a coordinated and cooperative approach based on open and transparent dialogue. The country-by-country report (CbCR) is a core element of this risk analysis.
    • aims to reduce disputes by providing greater multilateral tax certainty. The programme provides multinational companies with a level of tax comfort, but not legal certainty comparable to that provided, for example, through an advance pricing arrangement (APA).
    • is designed to analyse international and cross-border tax risks. This includes risks relating to transfer pricing, permanent establishments and other international tax issues such as hybrid arrangements, withholding tax and the benefits arising from double taxation treaties.

    Description and guidelines of the ICAP programme

    List of countries participating in the ICAP programme

    Contact: international.taxation@minfin.fed.be

  • European Trust and Cooperation Approach (ETACA)

    The European Trust and Cooperation Approach (ETACA) is an initiative developed by the European Commission as part of the Action Plan for fair and simple taxation supporting the recovery (Package for fair and simple taxation - European Commission). Belgium is an active participant in this programme.

    The ETACA programme:

    • is a non-legislative initiative based on the voluntary participation of multinational companies.
    • is based on a joint high-level risk assessment, carried out within a short, predefined timeframe by several EU Member States.
    • has as main objective to facilitate and promote tax compliance in order to prevent differences of opinion between tax administrations and multinational companies.
    • establishes a framework for promoting an open and transparent dialogue between the tax administrations involved and the participating multinationals. As with ICAP, the country-by-country report is a core element of this analysis.
    • focuses primarily on transfer pricing risks related to routine and non-complex transactions and offers practical tax certainty (a certain level of comfort) but not legal certainty (similar to ICAP).

    Description and guidelines of the ETACA programme

    Contact: international.taxation@minfin.fed.be

  • Mutual Agreement Procedure / Advance Pricing Arrangement (APA)

     FAQ Mutual Agreement Procedure / Advance Pricing Arrangement (APA) (PDF, 77.68 KB)