ARTICLE 2

Taxes Covered

(1) The taxes which are the subject of this Convention are:

(a) In the case of the United States, the Federal income taxes imposed by the Internal Revenue Code, hereinafter referred to as the “United States tax”, and

(b) In the case of Belgium:

(i) The individual income tax (l’impôt des personnes physiques); (ii) The corporate income tax (l’impôt des sociétés); (iii) The income tax on legal entities (l’impôt des personnes morales); (iv) The income tax on nonresidents (l’impôt des non-résidents); (v) The prepayments and additional prepayments (les précomptes et compléments de précomptes); and

(vi) Surcharges (centimes additionnels) on any of the taxes referred to in (i) through (v), including the communal supplement to the individual income tax (la taxe communale additionnelle à l’impôt des personnes physiques), hereinafter referred to as the “Belgian tax”.

(2) This Convention shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Convention in addition to, or in place of, existing taxes.

(3) The competent authorities of the Contracting States shall notify each other of any amendments of the laws imposing the taxes referred to in paragraph (1) and of the adoption of any taxes referred to in paragraph (2) by transmitting the texts of any amendments or new statutes at least once a year.

(4) The competent authorities of the Contracting States shall notify each other of the publication by their respective Contracting States of any material concerning the application of this Convention, whether in the form of regulations, rulings, or judicial decisions, by transmitting the texts of any such materials at least once a year.