Article 3 contains general definitions of various terms found in the convention.…
U.S. Income Tax Treaty — Belgium Income Tax Treaty - 1970 · 2026-10-03 edition · updated 2026-10-04 · United States
"resident" as applied to the determination of fiscal domicile in the two countries. Article 5 contains the definition of "permanent establishment". Under the convention business profits derived by a resident of one of the contracting states may be taxed by the other contracting state only if the resident maintains a "permanent establishment" in that other state to which the profits are attributable.
The credit provisions and related provisions dealing with relief from double taxation are set forth in Article 23. Article 24 contains the provisions regarding nondiscrimination (the so-called nationaltreatment provisions).
Articles 25-28 contain provisions relating to cooperation between the competent authorities of the two countries in effectuating the purposes of the convention. Article 28 also contains the provision that nothing in the convention shall affect the fiscal privileges of diplomatic and consular officers under the general rules of international law or provisions of special agreements.
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