On 24 June 2009, Belgium and the United Kingdom signed an amending protocol (the Protocol) to the income tax treaty of 1 June 1987 (the Treaty). The Belgian procedure to ratify the Protocol is complete and the Protocol was published in the Belgian Official Gazette of 28 December 2012.

The Protocol essentially brings the Treaty in line with the 2008 OECD Model Treaty and entered into force on 24 December 2012. The most welcome changes introduced by the Protocol relate to interest withholding tax and to the tax treatment of income from hybrid entities.

Further details are available from the Ernst & Young Tax Alert which can be accessed using the link below:

• Belgium-UK protocol amending tax treaty enters into force (PDF, 906 KB)

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