QROPS Advice: Taxation of Expatriates Living in Belgium

An expatriate living in Belgium will become liable to Belgian income tax, as residence rather than domicile is the relevant determining factor.
A resident of Belgium is defined as someone who has a family home or a place from where they manage their personal wealth/business/occupation in Belgium. People are automatically presumed to be resident of Belgium if their family lives in Belgium
and/or if they are registered in the Belgian population register.
Where an expatriate is resident in Belgium for only part of a tax year, income for that period is treated as if it were for a full year and full annual allowances can be claimed, as can the full bands for progressive rates of tax.
Expatriates that become permanently resident in Belgium are liable to inheritance tax on their worldwide assets. Any gifts, not already subject to gift tax, made three years prior to death will be added to the value of the estate. Inheritance tax rules differ according to the region where the deceased had their fiscal residence and the heir’s relationship with the deceased.
Foreign inheritance taxes paid on property situated abroad owned by a deceased Belgian resident can be deducted from Belgian tax payable on that property under certain conditions.
Expatriates may be considered to be tax resident in more than one country, but double taxation treaties between Belgium and many expatriates’ home countries should ensure that double taxation is avoided. Belgium has negotiated over 90 double taxation agreements.

http://www.ailo.org/common/externalPage.asp?intURL=/publications/default.asp&extURL=/downloads/Belgium_2009.pdf