The Swiss Federal Tax Administration has published a mutual agreement signed with Belgium on 3 July 2023 on the implementation of the arbitration process pursuant to paragraph 5 of Article 25 (Mutual Agreement Procedure) of the 1978 tax treaty between the two countries. As amended by the 2014 protocol, Article 25 generally provides that if a person's case cannot be resolved within 2 years, any unresolved issues arising from the case shall be submitted to arbitration if the person so requests…