Belgian GAAR under closer judicial scrutiny: two recent decisions define both its reach and its limits
I. Introduction The Belgian general anti-abuse rule, set out in article 344, §1 Belgian Income Tax Code 1992 (hereafter BITC92), has long occupied a central place in tax controversy. It is also one of the most litigated areas of Belgian tax law, precisely because it sits at the intersection of two competing principles. On the […]