OrbitaxBelgium Issues Draft Circular on Tax Consequences of Asset Transfers between a Head Office and PE under Tax Treaty Article 7 (Business Profits)
|Treaty Development|Belgium
On 5 September 2016, the Belgian Ministry of Finance released a draft circular on the interpretation of Article 7 (Business Profits) of the Belgian Model Tax Treaty. The circular covers the fundamental differences between Article 7 of the OECD Model Convention as it reads before and after 2010. In particular, the circular examines the tax consequences of the transfer of an asset between the hea…
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