29First, in the dispute in the main proceedings, it is common ground that under the convention for the prevention of double taxation as applied in Belgium, income from immovable property of property situated in France is not taxed in Belgium, whereas income from immovable property of property situated in Belgium is included in the basis of assessment. However, that convention allows the Belgian authorities to take account of income from immovable property of property situated in France for the purpose of determining, in accordance with the ‘maintenance of progressivity’ provided for by the convention, the tax rate applicable to income taxable in Belgium.
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