The Belgian tax authority recently published a ruling on the application of the 0% withholding tax rate for dividends provided under the 1978 income and capital tax treaty with Switzerland as amended by the 2014 protocol ({News-2017-08-10/T/3-previous coverage}). The protocol applies from 1 January 2018 and includes the replacement of paragraph 2 of Article 10 (Dividends) to provide for a withholding tax rate of 0% if the beneficial owner directly holds at least 10% of the paying company's ca…