Belgium is in contact with Austria to make adaptations specifically concerning art. 25 of the treaty (given the reservations Austria made under art. 16 MLI).
Belgium has taken action - next to notifying treaties as CTAs to the BEPS MLI - by negotiating and concluding complying instruments to make treaties in line with the action 14 Minimum Standard (e.g. Algeria [protocol sent, but not yet signed], Switzerland [ongoing negotiations], Norway [signed, but not yet in force]).
Negotiations for a new DTA are ongoing with Germany.
New DTA signed with France on 09.11.2021, but not entered into force yet.
New DTA signed with The Netherlands on 21.06.2023, but not entered into force yet.
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
OECD/G20 Base Erosion and Profit Shifting Project
Belgium
Recent developments relating to MAP in Belgium prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
EU directive 2017/1852 transposed in Belgian Law.
Latest Action 14 Peer Review report
13 August 2019 - https://doi.org/10.1787/734c25f4-en
Tax treaty network of Belgium
95 treaties in force (the treaty with Taipei is included, the treaties with USSR and ex-Yugoslavia are not counted as additional treaties).
status of MLI: in force.
Table 1. State of play of Belgium's tax treaty network
Source: OECD
Belgium's MAP programme
Organisation of competent authority function
17 persons:
one head of unit
15 persons working on MAP cases (among which eight persons work on other tasks as well):
of which four persons work on attribution/allocation cases and eleven persons work on other cases.
one person working on administrative duties.
contact persons for MAP requests:
Federal Public Service Finance, Belgium
North Galaxy A24, Koning Albert II laan 33 bus 515, 1030
Brussel Email: map.apa@minfin.fed.be.
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Belgium's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-belgium.pdf for details with respect to Belgium's MAP Statistics.
Figure 2. Cases closed in 2022
Source: OECD
Figure 3. Evolution of Belgium's MAP caseload (2016-22)
Source: OECD
Table 3. Overview of Belgium’s MAP caseload for 2022
Source: OECD
Table 4. Belgium’s average time to resolve MAP cases in 2022
Source: OECD