Transposition of ATAD GAAR in Belgium

Philippe Malherbe


In Belgium, the general anti abuse rule in matters of corporate income tax included in the anti-tax abuse directive has not been specifically transposed. We can however admit that the existing domestic rule against abuse in matters of income tax, viz. art. 344 § 1 of the Code of Income taxes, constitutes an adequate transposition.



taxation; Belgium; abuse; ATAD; transposition

DOI: 10.6092/issn.2036-3583/10810


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