DT3473 - DT: Belgium: double taxation agreement SI 1987 No.2053, Article 24: Non-discrimination

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.

(2) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.

(3) Nothing in this Article shall be construed as preventing Belgium:

(a) from taxing the total amount of the profits attributable to a permanent establishment in Belgium of a company being a resident of the United Kingdom or of an association having its place of effective management in the United Kingdom at the rate of tax provided by the Belgian law, but this rate may not exceed the maximum rate applicable to the whole or a portion of the profits of companies which are residents of Belgium;

(b) from imposing the movable property prepayment on dividends derived from a holding which is effectively connected with a permanent establishment or a fixed base maintained in Belgium by a company which is a resident of the United Kingdom or by an association which has its place of effective management in the United Kingdom and is taxable as a body corporate in Belgium.

(4) Nothing contained in this Article shall be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes, on account of civil status or family responsibilities or any other personal circumstances, which it grants to its own residents.

(5) Except where the provisions of paragraph (1) of Article 9, paragraph (6) of Article 11, or paragraph (4) of Article 12 of this Convention apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.

(6) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first- mentioned State are or may be subjected.

(7) The provisions of this Article shall apply to taxes of every kind and description.