Belgian-Swiss double taxation convention Amendment takes effect

On 10 April 2014 Belgium and Switzerland signed an Amendment of the Convention on preventing double taxation for taxes on income and on assets. This Amendment entails a number of significant innovations. For example, the Amendment contains an article on exchanging information within the double taxation convention between Belgium and Switzerland, with this provision being the basis for lifting Swiss banking secrecy in respect of the Belgian tax authorities.

The Amendment also includes new (and relaxed) legislation concerning the exemption from taxes levied at source on certain moveable incomes, such as dividends and interest. Aside from these, the Amendment has also altered a number of issues in the Belgian-Swiss double taxation convention that concern transfer pricing, property companies, pensions, tax fraud regulations, avoiding double taxation and others.

The Amendment took effect on 19 July 2017 and applies to:

  • Taxes levied at source (interest, dividends, etc): income paid or payable as of 1 January 2018
  • Other income taxes: income from tax periods that start after 1 January 2018 
  • Taxes according to assets: taxation of assets pertaining to tax periods that start after 1 January 2018
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