Belgium's tax treaty policy and the Draft Belgian Model Convention

This article examines Belgium's tax treaty policy and the Draft Model Convention published in 2007. After describing Belgium's current tax treaty network and giving some general comments on the Belgian Model, the article analyses some of its provisions and compares them to the comparable provision of the OECD Model. The article discusses, among other things, the use of the OECD Commentary to interpret the Belgian Model, transparent entities, and the provisions on associated enterprises, dividends, interest and royalties and capital gains. The article also considers the mutual agreement procedure, exchange of information and treaty abuse.