🇧🇪 Belgium — 🇳🇱 Netherlands

Tax Treaty / Double Tax Avoidance Agreement detail

New treaty signed 21 June 2023 by Belgium and the Netherlands, replacing the 2001 convention; the new treaty has not yet entered into force pending ratification (status as of mid-2025); the 2001 convention remains operative meanwhile; significant cross-border worker community (~50,000 Belgian commuters into NL each day, and ~25,000 Dutch into Belgium); Belgium's 30% special tax regime for foreign executives (replaced by inbound regime 2022); Netherlands 30% ruling reduced to 30/27/24 over years; EU directives Parent-Subsidiary, Interest/Royalties eliminate most intra-corporate withholding; MLI signed by both — Belgium ratified 2019, Netherlands ratified 2019; arbitration via MLI; social security coordination via EU Reg 883/2004 + Belgian-Dutch bilateral; particular issue: 2023 treaty introduces stricter PE rules and addresses hybrid mismatches under BEPS Action 2.