A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied:    
 - The control test: the Belgian taxpayer owns with or without its associated entities the majority of the voting rights attached to the total of the shares of the foreign company, or holds together with its associated entities a stake of at least 50% in the capital of this company, or is together with its associated entities entitled to at least 50% of the profits of this company; and     
- The taxation test: in the country or jurisdiction where it is situated, the foreign company/PE is either not subject to income tax or subject to income tax less than half of the income tax if the company/PE would have been located in Belgium.