New France–Belgium Tax Treaty (Part I): Real Estate & Treaty Overview

On 9 November 2021, France and Belgium signed a new tax treaty covering income and wealth taxation. Once ratified by both countries, it will replace the 1964 convention and is expected to enter into force on 1 January 2023 at the earliest.

This treaty reflects the latest OECD standards and integrates BEPS (Base Erosion and Profit Shifting) project elements. It includes significant updates on the concept of tax residence, covered taxes, capital gains, real estate treatment, and anti-abuse clauses.

This first part of the alert focuses on:

• Taxation of real estate between the two countries

• Clarification of residence rules

• Overview of treaty changes