The Double Tax Avoidance Agreement is a crucial international tax treaty implemented when there is significant economic interaction between Belgium and another country, necessitating clear rules to prevent double taxation of cross-border income. This agreement becomes essential when businesses and individuals face potential taxation in both Belgium and the treaty partner country for the same income. The document follows the OECD Model Tax Convention framework while incorporating specific Belgian tax law requirements and EU regulations. It typically includes comprehensive provisions covering various types of income, methods for eliminating double taxation, anti-abuse measures, and procedures for resolving tax disputes. The agreement is particularly important given Belgium's position as a key European business hub and its extensive international trade relationships, ensuring tax efficiency and certainty for cross-border operations while maintaining compliance with both Belgian and international tax standards.
Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.
Your data doesn't train Genie's AI
You keep IP ownership of your docs
1. Parties: Identification of the contracting states entering into the agreement
2. Background: Context and purpose of the agreement, including the intention to eliminate double taxation
3. Definitions: Definitions of key terms used in the agreement, including 'resident', 'permanent establishment', and types of income
4. Scope of Agreement: Specification of taxes and persons covered by the agreement
5. Residence: Rules for determining tax residence and resolving dual residence issues
6. Permanent Establishment: Definition and conditions constituting a permanent establishment
7. Income from Immovable Property: Taxation rules for income derived from real estate
8. Business Profits: Rules for taxation of business income and profit attribution
9. Associated Enterprises: Provisions regarding transfer pricing and related party transactions
10. Dividends, Interest, and Royalties: Taxation rules for investment income and intellectual property payments
11. Capital Gains: Treatment of gains from alienation of property
12. Employment Income: Rules for taxation of salaries, wages, and other employment remuneration
13. Elimination of Double Taxation: Methods and procedures for avoiding double taxation
14. Non-discrimination: Provisions ensuring fair treatment of residents of both states
15. Mutual Agreement Procedure: Procedures 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 procedures for terminating the agreement
1. Government Service: Special provisions for government employees and officials, included when significant government service arrangements exist between countries
2. Artists and Sportspersons: Special rules for entertainers and athletes, included when significant cultural exchange exists
3. Students: Provisions for students and trainees, included when there is significant educational exchange
4. Offshore Activities: Special provisions for offshore operations, included when dealing with countries with significant offshore industries
5. Technical Services: Specific provisions for technical service fees, included when significant technical cooperation exists
6. Limitation of Benefits: Anti-abuse provisions, included when there are concerns about treaty shopping
7. Most Favored Nation Treatment: Provisions ensuring equal treatment with other tax treaties, included in treaties with developing countries
8. Tax Sparing: Special provisions for tax incentives recognition, typically included with developing countries
1. Schedule A - Taxes Covered: Detailed list of specific taxes in each contracting state covered by the agreement
2. Schedule B - Competent Authorities: Designation and contact details of competent authorities in each state
3. Schedule C - Exchange of Information Procedures: Detailed procedures and formats for information exchange between authorities
4. Schedule D - Mutual Agreement Procedure Guidelines: Detailed steps and timelines for dispute resolution
5. Appendix 1 - Forms and Certificates: Standard forms for tax residence certification and treaty benefits claims
6. Appendix 2 - Rate Tables: Detailed tables of applicable tax rates for different types of income
7. Appendix 3 - Anti-abuse Provisions: Detailed explanations and examples of anti-abuse rules
8. Protocol: Additional agreements or clarifications on specific provisions of the main agreement
Find the exact document you need
Advance Transfer Pricing Agreement
A Belgian law agreement between taxpayer and tax authorities establishing approved transfer pricing methodologies for future intercompany transactions.
Download
Global Minimum Tax Agreement
Belgian law agreement implementing OECD Pillar Two global minimum tax requirements for multinational enterprises, ensuring compliance with EU and national legislation.
Download
Tax Indemnity Agreement
A Belgian law-governed agreement establishing tax indemnification obligations between parties, defining tax risk allocation and related procedures.
Download
Double Tax Avoidance Agreement
A Belgian-law governed bilateral treaty preventing double taxation between Belgium and a partner country, establishing comprehensive rules for cross-border taxation and tax relief.
Download
Double Tax Agreement
A Belgian Double Tax Agreement is a bilateral treaty preventing double taxation and tax evasion between Belgium and another country, following OECD guidelines and EU regulations.
Download
Bilateral Advance Pricing Agreement
A Belgian-law governed agreement between tax authorities and corporate entities establishing approved transfer pricing methodologies for cross-border intercompany transactions.
Download
Instalment Agreement
A Belgian law-governed agreement establishing structured payment terms for debt repayment through regular instalments.
Download
Taxation Agreement
A legal agreement governed by Belgian law that establishes tax arrangements and compliance requirements between parties under Belgian federal and regional tax legislation.
Download
Unilateral Advance Pricing Agreement
A binding agreement with Belgian tax authorities establishing approved transfer pricing methodologies for cross-border transactions.
Download
Tax Allocation Agreement
A Belgian law-governed agreement establishing tax allocation arrangements between group companies, including tax liability distribution and compliance requirements.
Download
Genie’s Security Promise
Genie is the safest place to draft. Here’s how we prioritise your privacy and security.
Your documents are private:
We do not train on your data; Genie’s AI improves independently
All data stored on Genie is private to your organisation
Your documents are protected:
Your documents are protected by ultra-secure 256-bit encryption
We are ISO27001 certified, so your data is secure
Organizational security:
You retain IP ownership of your documents and their information
You have full control over your data and who gets to see it
.png)
.png)