Context

As you may know, Article 15 of the OECD Model Convention defines where salaries derived by a resident of one country in respect of an employment carried out in the other country should be taxed. As a rule, subject to the application to the so-called “183 days rule”, pay is taxable in the country where the employment has been carried out.

News

The Belgian tax authorities have totally revisited their commentary of Article 15 of the OECD. How the Belgian tax authorities intend to apply the “employment article” of the double tax treaties in the future is published in a Practice Note dated 25 May 2005 that has just been posted on the tax authorities’ web site. This note also clarifies how, further to the recent OECD guidelines in this matter, the Belgian tax authorities intend to cope with cross-border income tax issues arising from stock options.

The Practice Note:
FR http://news.hrservices.be?lk200506031
NL http://news.hrservices.be?lk200506032