The Dissenting Interpretation of the Term “Immovable Property” in the Treaty of 1964 between Belgium and France and the Outcome of the Discussion in Their New Treaty

Caroline Docclo

doi:10.18778/8331-399-3

The Dissenting Interpretation of the Term “Immovable Property” in the Treaty of 1964 between Belgium and France and the Outcome of the Discussion in Their New Treaty

Caroline Docclo

Université de Liège; Université libre de Bruxelles

Publication:

Challenges of Contemporary Tax Law: Jubilee Book Dedicated to Professor Włodzimierz Nykiel. Volume II

Pages: 113-130

DOI: https://doi.org/10.18778/8331-399-3.11

Keywords: tax law, development of tax law, taxpayers’ rights, Włodzimierz Nykiel

Published: 23 December 2024

Categories: Law, Open Access

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This contribution illustrates the inability of the Belgian and French authorities and courts to agree on the interpretation the term “immovable property” (bien immobilier) used in the double tax treaty of 10 March 1964 between Belgium and France when characterizing shares in French real estate companies for the purposes of distributing the power to tax dividends or capital gains derived from those shares.

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This work is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.

How to Cite

Docclo, Caroline. 2024. “The Dissenting Interpretation of the Term ‘Immovable Property’ in the Treaty of 1964 Between Belgium and France and the Outcome of the Discussion in Their New Treaty”. In Challenges of Contemporary Tax Law: Jubilee Book Dedicated to Professor Włodzimierz Nykiel. Volume II, edited by Ziemowit Kukulski and Małgorzata Sęk, 113-30. Poland: Lodz University Press. https://doi.org/10.18778/8331-399-3.11.