The New US-Belgium Double Tax Treaty (1 livre + 1 livret)

Based on a study from the US Department of Commerce, the United States exported USD 18.7 billion worth of goods and services to Belgium in 2005 and imported USD 13.0 billion worth of goods and services from Belgium during that same year. Those numbers atone clearly illustrate the significance of the trade between the United States and Belgium.

On 27 November 2006, the United States and Belgium entered into a new Double Tax Treaty that further reduces tax barriers to capital and labour mobility. The Treaty provides, amongst other provisions, for the elimination of source-country withholding taxes on qualifying dividends; a much coveted provision by US trading partners. Also, it includes a mandatory arbitration provision, which applies to certain double taxation cases that cannot be resolved by the competent authorities within a specified timeframe. It is currently one of only three US tax treaties to include such a provision.

This book offers an in-depth analysis of the Treaty by high-profile Belgian and US tax practitioners, all of whom have extensive experience in cross-border transactions between the United States and Belgium. The book also discusses the many opportunities offered by the Treaty and their practical applications, as well as certain interpretative issues and how those can he resolved. In recognition of the growing competition among jurisdictions for inbound investments, the authors have also analysed how the Treaty compares with certain US tax treaties with other EU Member States and how the EC Treaty affects the application of the Treaty. Finally, this book also contains an introductory chapter highlighting how certain US domestic tax rules may impact upon the application of the Treaty.

This bookdis a unique tool for any practitioner, lawyer or consultant faced with an issue of cross-border investment, employment or other transactions between the United States and Belgium.

Editor : Anne Van de Vijver.