The issue has been discussed numerous times over the years. For more than 35 years the current special tax regime for foreign executives is being granted and applied without legal basis (as it is based on a tax circular of 8 August 1983). The Belgian Cour des Comptes and courts criticized the regime more than once. We can state that all parties involved knew and accepted an “update” was needed.
The real question was how to modify or to replace the existing regime?