The New US-Belgium Double Tax Treaty

The New US-Belgium Double Tax Treaty

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Van dit werk resten nog een aantal exemplaren. Indien u dit werk wenst te bestellen, gelieve contact te nemen met, tel +32(0)9 269 97 96 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 alone 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 be 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 book is 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.These doctrines have been used by the Service to re-characterize the form of certain transactions and the tax consequences ... 2001), affg T.C. Memo 1999-41 1, cert, denied, 122 S.Ct. 903 (2002); Northern Indiana Public Service Company v .

Title:The New US-Belgium Double Tax Treaty
Author:Anne Van de Vijver
Publisher:Larcier - 2009-01-27


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