ARTICLE 15
U.S. Income Tax Treaty — Belgium Income Tax Treaty - 1970 · 2026-10-03 edition · updated 2026-10-04 · United States
Dependent Personal Services
(1) Wages, salaries, and similar remuneration derived by an individual who is a resident of one of the Contracting States from labor or personal services performed as an employee, including income from services performed by an officer of a company, may be taxed by that Contracting State. Except as provided by paragraph (2) and Article 20 (Teachers) and Article 21 (Students and Trainees) such remuneration derived from labor or personal services performed in the other Contracting State may also be taxed by that other Contracting State.
(2) Remuneration described in paragraph (1) derived by an individual who is a resident of one of the Contracting States shall be exempt from tax by the other Contracting State if:
(a) He is present in that other Contracting State for a period or periods aggregating less than 183 days in the taxable year;
(b) He is an employee of a resident of the first-mentioned Contracting State or of a permanent establishment maintained in the first-mentioned Contracting State; and
(c) The remuneration is not borne as such by a permanent establishment which the employer has in that other Contracting State.
(3) Notwithstanding paragraphs (1) and (2), remuneration derived by an individual from labor or personal services performed as an employee aboard ships or aircraft registered in one of the Contracting States and operated by a resident of that Contracting State in international traffic shall be exempt from tax by the other Contracting State if such individual is a member of the regular complement of the ship or aircraft.
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