Treaty Series Recueil des Traites - United Nations Treaty Collection ...
Treaty Series Recueil des Traites - United Nations Treaty Collection ... Treaty Series Recueil des Traites - United Nations Treaty Collection ...
Volume 2223, 1-39522 [ ENGLISH TEXT - TEXTE ANGLAIS ] CONVENTION BETWEEN THE KINGDOM OF BELGIUM AND THE RE- PUBLIC OF LATVIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the Kingdom of Belgium, and The Government of the Republic of Latvia, Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows Chapter I. - Scope of the Convention Article 1. Personal scope This Convention shall apply to persons who are residents of one or both of the Contracting States. Article 2. Taxes covered 1. This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation. 3. The existing taxes to which the Convention shall apply are in particular: a) in the case of Latvia : i) the enterprise income tax (uznemumu ienakuma nodoklis); (ii) the personal income tax (iedzivotaju ienakuma nodoklis); hereinafter referred to as "Latvian tax") b) in the case of Belgium: i) the individual income tax; (ii) the corporate income tax (iii) the income tax on legal entities; (iv) the income tax on non-residents; (v) the supplementary crisis contribution; including the prepayments, the surcharges on these taxes and prepayments, and the supplements to the individual income tax ;
hereinafter referred to as "Belgian tax"). Volume 2223, 1-39522 4. The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws. Chapter II. - Definitions Article 3. General definitions 1. For the purposes of this Convention, unless the context otherwise requires: a) the term "Latvia" means the Republic of Latvia and, when used in the geographical sense, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the laws of Latvia and in accordance with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub-soil and their natural resources ; b) the term "Belgium" means the Kingdom of Belgium ; used in a geographical sense, it means the territory of the Kingdom of Belgium, including the territorial sea and any other area in the sea and in the air within which the Kingdom of Belgium, in accordance with international law, exercises sovereign rights or its jurisdiction ; c) the terms "a Contracting State" and "the other Contracting State" mean Latvia or Belgium, as the context requires ; d) the term "person" includes an individual, a company and any other body of persons ; e) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes in the Contracting State of which it is a resident ; f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State ; g) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State ; h) the term "competent authority" means: i) in the case of Latvia, the Ministry of Finance or its authorised representative; (ii) in the case of Belgium, the Minister of Finance or his authorised representative; i) the term "national" means : (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State. 2. As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has at that time under the law of that State for the purposes of the taxes to which
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hereinafter referred to as "Belgian tax").<br />
Volume 2223, 1-39522<br />
4. The Convention shall apply also to any identical or substantially similar taxes<br />
which are imposed after the date of signature of the Convention in addition to, or in place<br />
of, the existing taxes. The competent authorities of the Contracting States shall notify each<br />
other of any significant changes which have been made in their respective taxation laws.<br />
Chapter II. - Definitions<br />
Article 3. General definitions<br />
1. For the purposes of this Convention, unless the context otherwise requires:<br />
a) the term "Latvia" means the Republic of Latvia and, when used in the geographical<br />
sense, means the territory of the Republic of Latvia and any other area adjacent to the territorial<br />
waters of the Republic of Latvia within which under the laws of Latvia and in accordance<br />
with international law, the rights of Latvia may be exercised with respect to the<br />
sea bed and its sub-soil and their natural resources ;<br />
b) the term "Belgium" means the Kingdom of Belgium ; used in a geographical sense,<br />
it means the territory of the Kingdom of Belgium, including the territorial sea and any other<br />
area in the sea and in the air within which the Kingdom of Belgium, in accordance with<br />
international law, exercises sovereign rights or its jurisdiction ;<br />
c) the terms "a Contracting State" and "the other Contracting State" mean Latvia or<br />
Belgium, as the context requires ;<br />
d) the term "person" inclu<strong>des</strong> an individual, a company and any other body of persons<br />
;<br />
e) the term "company" means any body corporate or any entity which is treated as<br />
a body corporate for tax purposes in the Contracting State of which it is a resident ;<br />
f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting<br />
State" mean respectively an enterprise carried on by a resident of a Contracting State<br />
and an enterprise carried on by a resident of the other Contracting State ;<br />
g) the term "international traffic" means any transport by a ship or aircraft operated<br />
by an enterprise of a Contracting State, except when the ship or aircraft is operated solely<br />
between places in the other Contracting State ;<br />
h) the term "competent authority" means:<br />
i) in the case of Latvia, the Ministry of Finance or its authorised representative;<br />
(ii) in the case of Belgium, the Minister of Finance or his authorised representative;<br />
i) the term "national" means :<br />
(i) any individual possessing the nationality of a Contracting State;<br />
(ii) any legal person, partnership or association deriving its status as such from the<br />
laws in force in a Contracting State.<br />
2. As regards the application of the Convention at any time by a Contracting State,<br />
any term not defined therein shall, unless the context otherwise requires, have the meaning<br />
which it has at that time under the law of that State for the purposes of the taxes to which