OrbitaxTreaty between Belgium and Netherlands – Court of Appeal Ghent holds stock of goods does not constitute PE
|Treaty Development|Belgium-Netherlands
In a decision of 16 January 2007 (reported 31 May 2007), the Court of Appeal Ghent (Hof van Beroep Gent) decided in a case on the existence of a permanent establishment (PE) under the 1970 Belgium-Netherlands tax treaty on income and capital (the "treaty"). Details of the case are summarized below.
(a) Facts. A Dutch distribution centre of an international group is responsible for the…
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