While the Belgian authorities have acknowledged that national measures aimed at controlling the Covid-19 pandemic raise significant uncertainty with respect to the tax treatment of cross-border workers, they have not adopted a general position on the issue. It follows that the criterion of physical presence for allocating the power of taxation between States, provided for in double taxation treaties, is, in principle, strictly applied.
Belgium has however concluded agreements on this subject with four States which constitute important economic partners: Germany, France, Luxembourg and the Netherlands.