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Constitutional Court On New Article 444 ITC: Good Faith Prevails, But Not On All Levels
The Belgian Constitutional Court has ruled on the temporal scope of a new tax regime that presumes good faith for first-time infringements, determining whether taxpayers involved in disputes over assessments issued before the law's effective date can benefit from more lenient treatment. The decision addresses three key challenges: the temporal limitation of the new rules, the exclusion of good-faith presumption for ex officio assessments, and the absence of an equivalent regime for VAT.
Loyens & Loeff
