The Belgian tax authority recently issued Circular Letter 2024/C/79 regarding the application of the so-called Cayman tax rules in cases where a legal structure (arrangement) is located in a country with which Belgium has a tax treaty. The Cayman tax rules essentially tax 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 tax residents as if they had directly received the income, which may incl…