ARTICLE 9

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

Associated Enterprises

This Article complements section 482 of the Internal Revenue Code of 1954 and confirms the power of each government to allocate items of income, deduction, credit, or allowance in cases in which a resident of one State is related to a resident of the other State if such related persons impose conditions between themselves which are different from conditions which would be imposed between independent persons. This provision is similar to the provision contained in the OECD Model Convention.

Provision is made in Article 25 (Mutual Agreement Procedure) for consultation and agreement between the two States where an allocation by either State results or would result in double taxation.

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

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

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