【法规名称】
【颁布时间】 2004-10-13
【法规编号】 37982 什么是编号？
【正 文】
第9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] Article 27 Limitation on benefits Notwithstanding the provisions of any other Article of this Agr-eement, a resident of a territory shall not receive the benefitof any reduction in or exemption from tax provided for in theAgreement by the other territory if the main purpose or one ofthe main purposes of such resident or a person connected withsuch resident was to obtain the benefits of this Agreement.CHAPTER VI.- FINAL PROVISIONS Article 28 Entry into force 1.The Belgian Office, Taipei and the Taipei Representative Offi-ce in Belgium shall notify each other in writing about the co-mpletion of the procedures required for the entry into forceof this Agreement in their respective territories. The Agreem-ent shall enter into force from the date on which the later ofthese written notifications is received. 2.The provisions of the Agreement shall have effect : a) in respect of taxes due or withheld at source on income cr-edited or payable on or after January 1 of the year next following the year in which the Agreement enters into force; b) in respect of other taxes charged on income of taxable per-iods beginning on or after January 1 of the year next foll-owing the year in which the Agreement enters into force. Article 29 Termination This Agreement shall remain in force indefinitely, but the Belg-ian Office, Taipei and the Taipei Representative Office in Belg-ium may terminate the Agreement, by giving written notice of te-rmination not later than the 30th June of any calendar year fromthe fifth year following that in which the Agreement enters intoforce. In such event, the Agreement shall cease to have effect:a) in respect of taxes due or withheld at source on income cred-ited or payable on or after January 1 of the year next follo-wing the year in which the notice of termination is given;b) in respect of other taxes charged on income of taxable perio-ds beginning on or after January 1 of the year next followingthe year in which the notice of termination is given. IN WITNESS WHEREOF the undersigned, being duly authorised there-to, have signed this Agreement. DONE in duplicate at Brussels, this 13th day of October 2004, inthe English language. FOR THE TAIPEIFOR THE BELGIAN OFFICE,REPRESENTATIVE OFFICE IN BELGIUM: TAIPEI: C. J. CHEN, Hugues MIGNOT, PROTOCOL At the moment of signing the Agreement between the Belgian Offi-ce, Taipei and the Taipei Representative Office in Belgium forthe avoidance of double taxation and the prevention of fiscalevasion with respect to taxes on income, the undersigned haveagreed upon the following provisions which shall form an integr-al part of the Agreement. 1.Ad Article 5, paragraph 4 and Article 7 : It is understood that where activities are deemed to be a per-manent establishment under paragraph 4 of Article 5, only pro-fits attributable to the activities performed through employe-es or other personnel or persons present in that other territ-ory may be taxed in that other territory. 2.Ad Article 11, paragraph 3: It is understood that the provision of subparagraph a) shallapply, a) in the case of the territory in which the taxation law isadministered by the Belgian Federal Public Service Finance:- to interest of a loan or a credit for which a financial support is granted after advice of the Committee for fin- ancial support to export (“Finexpo”); - to interest of a loan or a credit granted by the Associa-tion for the coordination of medium-term financing of Be- lgian export (“Creditexport”); - to interest of a loan or a credit insured by the NationalOffice of Del Credere;. b) in the case of the territory in which the taxation law isadministered by the Taxation Agency, Ministry of Finance, Taipei, to interest received by the instrumentalities whichaim at promoting export and are approved by that Agency. 3.Ad Article 15, paragraph 1 : It is understood that an employment is exercised in a territo-ry when the activity in respect of which the salaries, wagesand other remuneration are paid, is effectively carried on inthat territory, this means when the employee is physically pr-esent in that territory for carrying on this activity there.4.Ad Article 22, paragraph 2 a) : Elements of income received by a resident of the territory inwhich the taxation law administered by the Belgian Federal Pu-blic Service Finance is applied, shall not be deemed to be ta-xed in the other territory when such income is not included inthe basis on which tax is due in that other territory. Conseq-uently elements of income which are not taxable or are exempt-ed in virtue of the legislation in force in that other territ-ory, shall not be considered to be taxed. IN WITNESS WHEREOF the undersigned, being duly authorised there-to, have signed this Protocol. DONE in duplicate at Brussels, this 13th day of October 2004, inthe English language. FOR THE TAIPEIFOR THE BELGIAN OFFICE,REPRESENTATIVE OFFICE IN BELGIUM: TAIPEI: C. J. CHEN, Hugues MIGNOT, |
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