Abstract
The purpose of this article is to serve as a warning' for trust practitioners around the world with regard to a new Belgian tax rule which might have extreme extraterritorial effects if a certain link with Belgium exists, i.e. in the event that a Belgian taxpayer can be identified as a founder' of the trust. Because both the scope and the exact workings of this tax rule are unclear, it is best to seek further advice if one doubts whether a transaction concerning a trust, or other 'legal construct' might trigger this tax. Precisely because of these uncertainties, the authors seek to identify possible routes by which this tax rule can be challenged.
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