【法规名称】
【颁布时间】 2004-10-13
【法规编号】 37982 什么是编号？
【正 文】
第6页 AGREEMENT BETWEEN THE TAIPEI REPRESENTATIVE OFFICE IN BELGIUM AND THE BELGIAN OFFICE, TAIPEI FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
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[接上页] in the fiscal year concerned; in that case, only so much income as is derived from his activities performed in thatother territory may be taxed in that other territory. 2.The term “professional services” includes especially indepe-ndent scientific, literary, artistic, educational or teachingactivities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.Article 15 Dependent personal services 1.Subject to the provisions of Articles 16, 18, and 19, salaries, wages and other similar remuneration derived by a residentof a territory in respect of an employment shall be taxableonly in that territory unless the employment is exercised inthe other territory.If the employment is so exercised, suchremuneration as is derived therefrom may be taxed in that oth-er territory. 2.Notwithstanding the provisions of paragraph 1, remunerationderived by a resident of a territory in respect of an employm-ent exercised in the other territory shall be taxable only inthe first-mentioned territory if : a) the recipient is present in the other territory for a peri-od or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxableperiod concerned, and b) the remuneration is paid by, or on behalf of, an employerwho is not a resident of the other territory, and c) the remuneration is not borne by a permanent establishmentor a fixed base which the employer has in the other territ-ory. 3.Notwithstanding the preceding provisions of this Article, rem-uneration derived in respect of an employment exercised aboarda ship or aircraft operated in international traffic, may betaxed in the territory in which the place of effective manage-ment of the enterprise is situated. Article 16 Directors’ fees 1.Directors' fees and other similar payments derived by a resid-ent of a territory in his capacity as a member of the board ofdirectors or a similar organ of a company which is a residentof the other territory may be taxed in that other territory.The preceding provision shall also apply to payments derivedin respect of the discharge of functions which, under the lawsin force in the territory of which the company isa resident,are regarded as functions of a similar nature as those exerci-sed by a person referred to in the said provision. 2.Remuneration derived by a person referred to in paragraph 1from a company which is a resident of a territory in respectof the discharge of day-to-day functions of a managerial ortechnical, commercial or financial nature and remuneration re-ceived by a resident of a territory in respect of his day-to-day activity as a partner of a company, other than a companywith share capital, which isa resident of a territory, maybe taxed in accordance with the provisions of Article 15, asif such remuneration were remuneration derived by an employeein respect of an employment and as if references to the "empl-oyer" were references to the company. Article 17 Artistes and sportsmen 1.Notwithstanding the provisions of Articles 14 and 15, incomederived by a resident of a territory as an entertainer, suchas a theatre, motion picture, radio or television artiste, ora musician, or as a sportsman, from his personal activities assuch exercised in the other territory, may be taxed in thatother territory. 2.Where income in respect of personal activities exercised by anentertainer or a sportsman in his capacity as such accrues notto the entertainer or sportsman himself but to another person,that income may, notwithstanding the provisions of Articles 7,14 and 15, be taxed in the territory in which the activitiesof the entertainer or sportsman are exercised. Article 18 Pensions and annuities 1.Pensions and other similar remuneration paid to a resident ofa territory in consideration of past employment, may be taxedin the territory in which they arise.This provision shallalso apply to annuities and to pensions and other similar rem-uneration paid by an entity of a territory under social secur-ity legislation in force in that territory or under a publicscheme organised by that territory in order to supplement thebenefits of that social security legislation. 2.The term “annuity” means a stated sum payable periodicallyat stated times during life or during a specified or ascertai-nable period of time under an obligation to make the paymentsin return for adequate and full consideration in money or mon-ey’s worth. Article 19 Government service 1.Salaries, wages and other similar remuneration, other than apension, paid by an authority administrating a territory or asubdivision thereof or by a local authority of that territoryto an individual in respect of services rendered to that auth-ority in the discharge of public or administrative functionsshall be taxable only in that territory. However, such salaries, wages and other similar remunerationshall be taxable only in the other territory if the servicesare rendered in that territory and the individual is a reside-nt of that territory who : |
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