ARTICLE 16

U.S. Income Tax Treaty — Belgium Income Tax Treaty - 1970 · 2026-10-03 edition · updated 2026-10-04 · United States

Directors’ Fees

Notwithstanding Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services), a director’s fee derived by an individual who is a resident of one of the Contracting States in his capacity as a member of the board of directors of a corporation of the other Contracting State (but not including fixed or contingent payments derived in his capacity as an officer or employee), which cannot be taken as a deduction by the corporation but is treated in that other Contracting State as a distribution of profits, may be taxed by that other Contracting State.

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▸Contents — U.S. Income Tax Treaty — Belgium Income Tax Treaty - 1970

U.S. Income Tax Treaty — Belgium Income Tax Treaty - 1970

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