A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied:  - The control test: the Belgian taxpayer owns (directly or indirectly) the majority of voting rights of the foreign company, or has (directly or indirectly) a stake of at least 50% in the capital of this company, or is 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 would have been located in Belgium.