ARTICLE 9

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

Associated Enterprises

(1) Where a resident of one of the Contracting States and a resident of the other Contracting State are related and where such related persons make arrangements or impose conditions between themselves which are different from those which would be made between independent persons, then any income which would, but for those arrangements or conditions, have accrued to the resident of the first-mentioned Contracting State but, by reason of those arrangements or conditions, has not so accrued, may be included in the income of the resident of the first-mentioned Contracting State for purposes of this Convention and taxed accordingly.

(2) A person is related to another person for purposes of this Convention if either person participates directly or indirectly in the management, control, or capital of the other, or if any third person or persons participates directly or indirectly in the management, control, or capital of both.

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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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