Article 7 (Business Profits), and not Article 14 or 15, shall apply to a partner's

U.S. Income Tax Treaty — belgium tax treaty documents: belgiumte07.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

distributive share of the income of an entity that is treated as fiscally transparent, such as a U.S. partnership.

This Article is subject to the saving clause of paragraph 4 of Article 1 (General Scope). Thus, if a U.S. citizen who is a resident of Belgium is a director of a U.S.

corporation, the United States may tax his full remuneration regardless of where he performs his services.

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▸Contents — U.S. Income Tax Treaty — belgium tax treaty documents: belgiumte07.pdf

U.S. Income Tax Treaty — belgium tax treaty documents: belgiumte07.pdf

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