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ARTICLE 11. RELATED PERSONS

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

This Article complements section 482 of the Internal Revenue Code of 1954 and confirms the power of each government to allocate items of income, deduc­ tion, credit, or allowances in cases in which a resident of one State is related to any other person if such related persons impose conditions between themselves which are different from conditions which would be imposed between inde­ pendent persons. This provision is similar to the provision contained In the

OECD Model Convention.

Provision is made in Article 28 (Mutual Agreement Procedures) for consul­ tation and agreement between the two States where an allocation by either State results or would result in double taxation.

BELGIUM 400

100

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▸Contents — U.S. Income Tax Treaty — Technical Explanation 1970
U.S. Income Tax Treaty — Technical Explanation 1970

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