Dispute resolution

Belgium Dispute Resolution Country Profile



last update 6 June 2016


Competent Authority

Mrs Sandra KNAEPEN - Advisor - General
International Relations - General Administration of Taxes
North Galaxy Koning Albert II laan 33 bus 22 / 1030 Brussels / Belgium

Tel +32 257 624 11 / Fax +32 257 992 22

Email: sandra.knaepen@minfin.fed.be


Dispute resolution, Bi- or Multilateral Advance Pricing Agreements: International Relations

Scope of MAP & MAP APA

  • Elimination of double taxation.
  • Application or interpretation of treaty provisions.
  • Avoid future double taxation by concluding Advance Pricing Agreements.

Domestic guidelines & administrative arrangements

Specific instructions with respect to the application of the Arbitration Convention of the EU circular letter AFA/Intern ISR/98-0170 of 07.07.2000 and AFA N° 6/2003 of 25.03.2003. Guidelines for conducting Advance Pricing Agreements under the mutual agreement procedure.

Time for filing

Dispute resolution : Terms determined by the double taxation convention (this term may vary between 6 months and 3 years).

APA : The request has to be filed before the transaction for which the request is made is realized.

Form of request

No specific form is required but the request has to be filed in writing and it has to be motivated.

Documentation requirement

The taxpayer has to produce the appropriate documents enabling the tax administration to decide whether his request is justified or not.

User fees


Tax collection / penalty / interest

At the request of the taxpayer collection is suspended during the mutual agreement procedure with respect to the amount of the tax that is contested.

If the request of the taxpayer is rejected, late payment interest will be calculated on the period of the tax collection. If the taxpayer has paid the tax, default payments are due in case of exemption of the tax at the end of the mutual agreement procedure.

The habitual rules apply.

Other dispute resolution mechanisms

Arbitration Convention within EU

Government Website




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