India–Belgium Tax Treaty Gets a Major Upgrade!
The protocol amending the India-Belgium Double Taxation Avoidance Agreement (DTAA) recently entered into force, with a notification issued by India’s Central Board of Direct Taxes (CBDT) on November 10, 2025. The “major upgrade” is the expansion of the scope of information exchange to curb tax evasion and avoidance effectively.
The Central Board of Direct Taxes (CBDT) has notified a Protocol amending the India–Belgium Double Taxation Avoidance Agreement (DTAA) , a big step toward greater tax transparency, cooperation, and enforcement between the two nations.
What’s New in the Amended DTAA
1️⃣ Wider Definition of “Competent Authority”
Under Article 3(1)(d), Belgium’s competent authority has been expanded.
Now it includes not only the Federal Minister of Finance, but also Ministers from Regional or Community Governments and their authorised representatives — ensuring smoother coordination across government levels.
2️⃣ New Definition – “Criminal Tax Matters”
A new clause Article 3(1)(k) defines criminal tax matters as intentional acts of tax evasion or fraud that are punishable under the requesting nation’s tax or criminal laws ,even if they occurred before the protocol came into effect.
3️⃣ Stronger “Exchange of Information” Clause
The old Article 26 has been replaced with a modern and more powerful version:
Information can now be shared if it is “foreseeably relevant” to enforcing tax laws or the DTAA.
Covers all types of taxes — not just income tax.
No banking secrecy excuse! Information cannot be denied simply because it’s held by a bank, fiduciary, or nominee.
This brings the treaty in line with OECD’s global standards on information sharing and boosts transparency in cross-border transactions.
4️⃣ Assistance in Collection of Taxes .
The older recovery article is replaced by Article 27 – Assistance in Tax Collection.
-Both countries must help each other recover legally enforceable tax debts, including interest, penalties, and recovery costs.
-Each nation will treat the partner’s tax claim as if it were its own debt.
Requests can be declined if they:
-Violate domestic laws or public policy, or
-If the requesting country hasn’t made reasonable recovery efforts first.
Why It Matters:
✅ Enhances tax cooperation between India & Belgium 🇮🇳🇧🇪
✅ Closes loopholes used for tax evasion & money laundering
✅ Promotes mutual assistance, transparency, and fair taxation
✅ Aligns India’s treaty framework with modern international tax norms
In short: The India–Belgium DTAA Protocol strengthens the fight against fiscal evasion, modernises data sharing, and ensures greater accountability across borders!
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