On 19 February 2019, the Antwerp Court of Appeals rendered decision 2017/AR/1184 on the issue whether a Belgian IT consulting firm had a permanent establishment in Morocco (articles 5, 7 and 23, 2, a) of the Belgium – Morocco Income Tax Treaty 2006). (a) Facts. A Belgian company provided, through its managing director, IT services … Continue reading Court of Appeal Antwerp requires proof of actual business activities, having a certain degree of permanence, at a specific location
