
International & wealth taxation
Optimising and securing the wealth of those whose interests cross borders.
The firm advises individuals, families and businesses whose wealth, income or activities span several countries. Our role: to determine where and how you are taxed, structure your wealth accordingly and secure every transaction — from advice to litigation. Our fields: double taxation treaties, tax residence and exit tax, holding and wealth-holding companies, advance rulings and international succession.
Understanding international & wealth taxation
When should you consult an international tax lawyer?
As soon as a border comes into play. In practice: you hold assets or companies abroad, you are relocating or settling in Belgium, you are preparing an international succession or sale, or you receive foreign-source income. The earlier you plan, the greater the room to avoid double taxation or a reassessment.
How can you avoid being taxed twice on the same income?
Through double taxation treaties. Belgium has concluded a broad network of them: they allocate taxing rights between States and, depending on the case, grant an exemption or a tax credit. The sensitive point remains the classification of each type of income and proof of your tax residence — this is where our work makes the difference.
What happens, tax-wise, if I leave Belgium?
A departure can trigger an “exit tax”. When you transfer your residence — or a company transfers its seat — out of Belgium, certain unrealised capital gains may be taxed as if realised at the time of departure. Well prepared, this change can be planned to control its timing and cost; poorly prepared, it triggers immediate taxation.
How can a transaction be secured before it is carried out?
Through an advance ruling. The Advance Rulings Service gives you, before the transaction, the tax administration's position on its treatment — a valuable guarantee of legal certainty for sensitive structures. We prepare and defend these applications.
How do you organise and pass on wealth spread across several countries?
By combining the right tools to serve a clear objective: holding companies, wealth-holding companies, dismemberments of ownership, tailored arrangements. The challenge is to reconcile tax efficiency, legal certainty and succession, while ensuring the economic substance of the structures — now closely scrutinised.
And in the event of an audit, a dispute or a voluntary disclosure?
We defend you at every stage. Beyond advice, the firm assists its clients in tax litigation before the administration and the courts, as well as in voluntary disclosure procedures.
What we handle
- International wealth and succession structuring
- Holding and wealth-holding companies
- Double taxation treaties
- Transfer pricing and intra-group flows
- Taxation of directors, executives and expatriates
- Tax residence, exit tax and change of residence
- Advance rulings and legal certainty
- Tax litigation and voluntary disclosure