Belgium-U.K. Protocol Enters Into Force

On Jun 24, 2009, Belgium and the UK signed an amending protocol (Protocol) to their income tax treaty of Jun 1, 1987. The Belgian procedure to ratify the Protocol is complete and the Protocol was published in the Belgian Official Gazette of Dec 28, 2012. It entered into force on Dec 24, 2012. The Pr...

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Bibliographic Details
Published in:Journal of International Taxation 2013-04, Vol.24 (4), p.6
Main Authors: Smeets, Arne, Stalenhoef, Dirk, Schoon, Frank, van Hulsen, Frank, Beer, Ian, Churton, Sarah, Joosten, Herwig, Huygen, Werner, Claes, Steven
Format: Article
Language:English
Subjects:
Corporate income tax
Dividends
Double taxation
Income taxes
International taxation
Partnership interest
Protocol
Provisions
Royalties
Tax exemptions
Tax rates
Tax services
Tax treaties
Withholding taxes
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Summary:On Jun 24, 2009, Belgium and the UK signed an amending protocol (Protocol) to their income tax treaty of Jun 1, 1987. The Belgian procedure to ratify the Protocol is complete and the Protocol was published in the Belgian Official Gazette of Dec 28, 2012. It entered into force on Dec 24, 2012. The Protocol essentially brings the treaty in line with the 2008 OECD Model Treaty. The most welcome changes that the Protocol introduces relate to interest withholding tax and the tax treatment of income from hybrid entities. The Protocol requires Belgium to exempt income derived by a Belgium resident if the income "is taxed" in the UK in accordance with the provisions of the income tax treaty, whereas the treaty formerly required Belgium to exempt income derived by a resident of Belgium if the income "may be taxed" in the UK in accordance with the provisions of the treaty.
ISSN:1049-6378