Article 16. DIRECTORS' FEES

This Article provides that, when a company which is a
resident of a Contracting State pays a fee to a resident of the
other Contracting State for services rendered as a director of

that company, the fee may be taxed in the first-mentioned State

if it is treated in that State as a distribution of profits which

may not be claimed as a deductible expense **by** the company.

Remuneration and fees to an individual for services performed as

a director which are a deductible expense to the company are
covered under Article 14 (Independent Personal Services) or **15**
(Dependent Personal Services), as appropriate. This Article is

similar to the corresponding provision in the U.S.-Belgium income tax treaty.