OrbitaxDifferent treatment of interest derived by Luxembourg PE of Belgian enterprise, and by Luxembourg fixed base of Belgian professional, under Belgium-Luxembourg treaty not incompatible with equality principle of Belgian constitution
|Treaty Development|Belgium-Luxembourg
On 1 February 2006, the Belgian Constitutional Court (Arbitragehof/Court d'Arbitrage) decided on the different taxation of interest on debt claims derived by a Luxembourg permanent establishment (PE) of a Belgian enterprise, and by a Belgian professional who has a fixed base in Luxembourg, under the Belgium-Luxembourg income and capital tax treaty of 17 September 1970 (the treaty). A prelimi…
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