There are no deemed residence rules in Belgian tax law. According to the Belgian interpretation of the expression “liable to tax”, effective taxation of the taxpayer’s worldwide income is not required in order to enjoy treaty protection. Belgian pension funds and collective securities investment companies (SICAV and SICAF) fulfill this condition, as they are liable to tax on their worldwide income in Belgium and therefore enjoy treaty protection although the majority of their income is exempt in Belgium. The same is true for legal persons who are subject to the income tax on legal entities (e.g. non-profit organizations) that are only taxable on some items of income.