Belgium's Council of Ministers has approved ratification of a protocol updating its 1978 tax treaty with Switzerland to align with OECD and G20 anti-tax avoidance standards, with the changes set to take effect from 1 January following the exchange of ratification instruments. 

RF Report

Belgium’s Council of Ministers has approved a draft law for the ratification of the protocol to the 1978 income and capital tax treaty with Switzerland on 13 May 2026.

Signed 16 July 2025, the protocol aims to align the 28 August 1978 tax treaty with the minimum standards of the OECD and G20 BEPS project aimed at combating base erosion and profit shifting. This alignment forms part of a broader global effort to enhance the substance, consistency, transparency, and legal certainty of the international tax system.

It will enter into force upon the exchange of ratification instruments and will generally apply from 1 January of the following year.

Earlier,  the Swiss Council of States approved ratification of the protocol to the 1978 income and capital tax treaty with Belgium on 9 March 2026.