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20 May 2014

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Update - New Tax Treaty between Belgium and Norway Signed

On 23 April 2014, officials from Belgium and Norway signed a new income tax treaty. Once in force and effect, the new treaty will replace the current treaty signed in April 1988 and its amending protocol signed in September 2009.

Taxes Covered

The treaty applies to the following Belgian taxes:

  • Individual income tax
  • Corporate income tax
  • Income tax on legal entities
  • Income tax on non-residents

The treaty applies to the following Norwegian taxes:

  • National tax on income
  • Municipal tax on income
  • County municipal tax on income
  • National tax relating to income from the exploration for and the exploitation of submarine petroleum resources and activities and related work, including pipeline transport of petroleum produced
  • National tax on remuneration to non-resident artistes

Withholding Tax Rates

  • Dividends - 0% if the beneficial owner directly holds at least 10% of the paying company's capital for a period of at least 12 months, otherwise 15% (current treaty: 5% if beneficial owner holds 25% or more of the paying company's capital, otherwise 15%)
  • Interest - 10% (current treaty 15%), although the following are exempt:
    • Interest paid in connection with a credit sale for goods, merchandise, equipment or services
    • Interest paid in respect of loans granted by a banking enterprise, except when represented by bearer instruments
    • Interest paid in respect of a credit or loan granted or extended by an enterprise to another enterprise
  • Royalties - 0%

Service PE

The treaty varies from the current OECD model and the current treaty between the two countries with the inclusion of provisions for a service permanent establishment (PE).

In general, a service PE will be deemed constituted when an enterprise from one country furnishes services in the other country through one or more individuals present in that other country for an aggregate period of 183 days or more in a 12 month period when for the same or connected project, or when 50% or more of the enterprise's gross revenue from business activities in such period(s) is derived from those services.

Double Taxation Relief

Under the treaty, Norway uses the credit method to eliminate double taxation while Belgium generally uses the exemption method.

Limitation on Benefits

A protocol to the treaty, signed the same date as the treaty, includes a limitation on benefits provision whereby the benefits of the treaty will not be applicable for income paid or derived in connection with an artificial arrangement.

Entry Into Force and Effect

The treaty will enter into force once the ratification instruments are exchanged and apply from 1 January of the year following the date of its entry into force. The 1988 treaty and 2009 protocol will terminate and cease to be effective from the date the new treaty goes into effect.

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