Belgian Court of Cassation rules Luxembourg Sicavs liable for Belgian subscription tax

Belgium's highest court upheld the state's right to levy subscription tax on Luxembourg Sicavs marketing shares in Belgium, rejecting the funds' reliance on the double-taxation convention. The ruling reverses prior appellate decisions and creates fiscal exposure for Luxembourg funds operating in Belgium. The decision's scope and retroactivity remain uncertain, but it may reshape cross-border fund distribution in the EU.