Double Tax Agreement Uk Belgium


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A political subdivision or territorial collectivity, the central bank of a Contracting State or an agency (other than an agency with registered capital) wholly owned by a Contracting State, a political subdivision or a territorial authority shall be deemed to be established in that Contracting State, whether or not it may be taxable in that Contracting State. The competent authorities of the States Parties may, by mutual agreement, designate any other State entity to which this paragraph applies. For the purposes of this Article, we consider a person to be resident for tax purposes in the United Kingdom and another country, although there are double taxation treaties between two countries. On 10 January 2020, the Government of the United Kingdom published the consolidated text of the 1987 Belgian-British Double Taxation Convention, as amended by the BEPS Multilateral Instrument. (c) Subparagraphs (a) and (b) of this paragraph shall apply only where satisfactory documents are filed for the competent authority of the other State Party that the fee has been paid in the Contracting State which is solely entitled to tax the compensation referred to in subparagraphs (a) and (b). Otherwise, the national laws of the Contracting States relating to the taxation of such remuneration shall apply and, where appropriate, the double taxation referred to in Article 23 of this Convention shall be attended. Determining the position of the person`s “contractual residence” is essential to determine whether it is possible to do so and how to apply a double taxation treaty, given that this is the country of contractual residence that generally assumes the taxing rights. 2. Where a State Party includes the profits of an enterprise of that State and taxes it accordingly, the profits on which an enterprise of the other State Party has been taxed in that other State, and the items so included shall include income, deductions, revenues or expenses that would have been charged to the enterprise of the first State if the conditions imposed between the two enterprises had been as follows: the competent authorities of the States Parties may then consult each other to reach agreement on the correction of gains or losses in both States Parties. . . .