EX-8.1

Exhibit 8.1


				ADVOCATEN \| AVOCATS
				GMB.TECH NV De Gerlachekaai 20 2000 Antwerp
				Belgium
				July 1, 2025

Nico Goossens*

Kris Verdoodt*

Philippe Rens*

Bert Van Ingelghem*

Pieter Bogaerts*

Hannes Casier*

Emilie Ooms*

Freya Jorens*

Louis Hoet*
Wouter Verhoeye*

Evelyn Van Raemdonck*

Henri Nelen*

Mattias Verbeeck

Francis Wijnakker*

Jolien Loos*

Hannelore Geldof*

Lawrence Geernaert*

Christophe Verhelst*

Pieter-Jan Van Goethem

Frederik Wilmots*

Michiel Vanwynsberghe*

Thomas Van Hoornyck*

Silke Chantrain*

Ben Nagar*

Madjda Temraz*

Lise Van Daele*

Aline Vermeulen*

Margaux Van Mol*

Julie Calaerts*

Andries Bots
Jasper Willems*

Julie Smets

Dorien Willemen*

Pierre Accou*

Andréas Kliché*
Steven Demeulenaere*

Michelle Werbrouck*
Arnout Coppieters*
Evelyne Claessens*

Esther De Schryder*

Kato Van Meel*

Maxime Collin*
Daan Vernimmen*

Don Baudewyns*
Lena Pepa
Silke Spruyt*

Charlotte Herpoelaert

Emiel Schepkens*
Flip Dalle

Rick Fremau
Emma Platevoet*

Maxim Vanschooren*

Thibaud De Bie*

Louise Rooms*
Laurens Matthys*

Alex Heyndrickx*
Laurens Vanhees*
Guido Platteau*
Manon Cornelis*
Eva Van Haudt

Re: CMB.TECH NV

Ladies and Gentlemen,

We have acted as Belgian legal counsel to CMB.TECH NV, a public limited liability company incorporated under the laws of the Kingdom of Belgium (the “Company”), in connection with the Company’s Registration Statement on Form F-4 as filed with the U.S. Securities and Exchange Commission on July 1, 2025, as thereafter amended or supplemented (the “Registration Statement”), with respect to the issuance of approximately 95,952,934 ordinary shares of the Company, no par value (the “Ordinary Shares”). Pursuant to the Agreement and Plan of Merger dated May 28, 2025, by and among the Company, CMB.TECH Bermuda Ltd. (“Merger Sub”) and Golden Ocean Group Limited (“Golden Ocean”) (the “Merger Agreement”), as described in the form of proxy statement/prospectus included in the Registration Statement (the “Proxy Statement/Prospectus”), the Registration Statement relates to the merger of Golden Ocean with and into Merger Sub, with Merger Sub as the surviving company as a wholly owned subsidiary of the Company (the “Bermuda Merger”). Following the Bermuda Merger, each Golden Ocean common share (other than the shares that Golden Ocean, the Company, Merger Sub or any of their respective subsidiaries own) will ultimately be converted into 0.95 Ordinary Shares. The Company will issue the Ordinary Shares in a capital increase following a contribution in kind as set out in the Belgian Code of Companies and Associations (the “Contribution in Kind” and together with the Bermuda Merger, the “Merger”).

We have examined originals or copies, certified or otherwise identified to our satisfaction, of: (i) the Registration Statement; (ii) the Proxy Statement/Prospectus included in the Registration Statement; (iii) the Merger Agreement and (iv) such corporate documents and records of the Company and such other instruments, certificates and documents as we have deemed necessary or appropriate as a basis for the opinions hereinafter expressed. In such examinations, we have assumed the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as copies or drafts of documents to be executed, the genuineness of all signatures and the legal competence or capacity of persons or entities to complete the execution of documents, and, as to factual matters, the truth, accuracy and completeness of the information, representations and warranties contained in the Registration Statement, including the Proxy Statement/Prospectus, the Merger Agreement and such other documents, agreements and instruments.

Based upon and subject to the foregoing, and the other assumptions, exclusions and qualifications in this letter, and in particular, on the representations, covenants, assumptions, conditions and qualifications described in the Proxy Statement/Prospectus under the heading “Material Tax Considerations” therein, we hereby confirm that the opinions that are attributed to Argo Law with respect to Belgian federal income tax matters expressed in the Proxy Statement/Prospectus under the heading “Material Tax Considerations – Belgian Tax Considerations” are the opinions of Argo Law and accurately state our views as to the tax matters discussed therein.

Argo Law bv

Post X

Borsbeeksebrug 28

2600 Antwerpen

T +32 3 206 85 30

Doorniksewijk 105

8500 Kortrijk

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Derdenrekening:

BTW:

www.argo-law.be

IBAN BE82 0016 9734 1968 BIC GEBABEBB

IBAN BE36 0017 0272 6781 BIC GEBABEBB

BE0533.993.314

*bv