Belgium : the concept of permanent establishment revisited and other reflections beyond

This article examines the concepts of "permanent establishment" and "Belgian establishment" and the differences between the two in the context of cross-border taxation. The article first reviews the international tax developments regarding PEs, the function of the PE concept and the tax developments in Belgium regarding PEs and Belgian establishments. The article then gives some reflections on the current issues in the twilight of unsettled case law and disputes in Belgian doctrine.