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Double Tax Agreement

Double Tax Agreement Template for Belgium

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Key Requirements PROMPT example:

Double Tax Agreement

"Need a Double Tax Agreement between Belgium and Singapore to be effective from March 2025, with specific provisions for digital services and software licensing, focusing on technology sector tax treatment and including clear permanent establishment rules for digital operations."

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Document background
Double Tax Agreements are essential international treaties used when businesses or individuals operate across borders between Belgium and another country. These agreements serve to prevent income from being taxed twice in different jurisdictions while also preventing tax evasion. The document becomes particularly relevant for companies establishing operations in Belgium or Belgian companies expanding internationally. It contains detailed provisions on tax residency, permanent establishments, various types of income taxation, and administrative procedures for implementation. As Belgium is an EU member state and a significant international business center, these agreements must align with both EU regulations and OECD standards while addressing specific aspects of Belgian tax law.
Suggested Sections

1. Parties: Identification of the contracting states entering into the agreement

2. Background: States the purpose of preventing double taxation and tax evasion between the contracting states

3. Definitions: Defines key terms including 'resident', 'permanent establishment', and other relevant terminology

4. Scope of Agreement: Specifies the taxes and persons covered by the agreement

5. Residence Rules: Establishes criteria for determining tax residence and resolving dual residence

6. Permanent Establishment: Defines and sets conditions for what constitutes a permanent establishment

7. Income from Immovable Property: Rules for taxing income derived from real estate

8. Business Profits: Provisions regarding taxation of business income

9. Associated Enterprises: Rules for dealing with related company transactions and transfer pricing

10. Dividends, Interest, and Royalties: Specific provisions for these types of passive income

11. Capital Gains: Rules for taxing gains from alienation of property

12. Employment Income: Provisions for taxing salaries and other employment compensation

13. Elimination of Double Taxation: Methods for avoiding double taxation (credit or exemption method)

14. Non-discrimination: Ensures fair treatment of residents of both states

15. Mutual Agreement Procedure: Process for resolving disputes between tax authorities

16. Exchange of Information: Framework for information sharing between tax authorities

17. Entry into Force: Provisions regarding when the agreement becomes effective

18. Termination: Conditions and process for terminating the agreement

Optional Sections

1. Independent Personal Services: Used when specifically addressing income from professional services - often included in older treaties but now usually covered under Business Profits

2. Artistes and Sportspersons: Special provisions for entertainers and athletes, included when significant cross-border entertainment activity exists

3. Pensions and Social Security: Specific provisions for retirement income, included when there is significant cross-border pension activity

4. Government Service: Special provisions for public sector employees, included when significant government service arrangements exist

5. Students: Provisions for students and trainees, included when significant educational exchange exists

6. Limitation on Benefits: Anti-abuse provisions, included when treaty shopping is a concern

7. Offshore Activities: Included when dealing with countries with significant offshore operations

8. Investment Funds: Special provisions for investment vehicles, included when significant fund activity exists between countries

Suggested Schedules

1. Protocol: Additional provisions clarifying or modifying specific articles of the main agreement

2. Schedule of Covered Taxes: Detailed list of specific taxes in each country covered by the agreement

3. Administrative Procedures: Detailed procedures for implementing the agreement's provisions

4. Exchange of Notes: Diplomatic notes exchanged between countries clarifying certain provisions

5. Most Favored Nation Provisions: List of provisions that may be automatically updated based on other treaties

6. Anti-Abuse Provisions: Detailed rules and examples regarding anti-abuse measures

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok成人版 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions



















































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Relevant Industries

Financial Services

International Trade

Manufacturing

Professional Services

Technology

Energy

Real Estate

Transportation & Logistics

Healthcare

Education

Media & Entertainment

Construction

Retail

Telecommunications

Relevant Teams

Finance

Legal

Tax

Treasury

Compliance

International Business Development

Corporate Secretariat

Human Resources

Risk Management

Government Relations

Relevant Roles

Tax Director

International Tax Manager

Chief Financial Officer

Financial Controller

Tax Consultant

Corporate Lawyer

Finance Manager

Compliance Officer

Treasury Manager

International Business Development Manager

Transfer Pricing Specialist

Tax Partner

Global Mobility Manager

International HR Manager

Corporate Secretary

Industries








Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks, 聽Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination, 聽Severance Pay, Governing Law, Entire Agreemen

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