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Belgian Constitutional Court Partially Annuls 2023 Cayman Tax Reform

|Approved Changes|Belgium
Belgium

Belgium's Constitutional Court has issued a release on its judgment of 18 September 2025 to partially annul reforms approved at the end of 2023 to the so-called "Cayman Tax" regime, which targets income from foreign legal constructions artificially separated from Belgian taxpayers. The Cayman Tax regime essentially provides for the taxation of income collected by a legal structure (e.g., a trust, certain low-tax companies, etc.) at the level of its founders or beneficiaries that are Belgian…

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