Advance ruling no. 800.065 of 11 March 2008 of the Belgian Ruling Committee (Dienst Voorafgaande Beslissingen), on the classification of income from real estate certificates under the Belgium-Luxembourg tax treaty on income and capital of 17 September 1970, was recently published. Details are summarized below.
(a) Facts and Issue. The case concerned a Luxembourg limited liability company (SARL X), which held real estate certificates issued by a Belgian company (SA Y…