Based on a study from the US Department of Commerce, the United States

exported USD 18.7 billion worth of goods and services to Belgium in 2005 and

imported USD 13.0 billion worth of goods and services from Belgium during

that same year. Those numbers alone clearly illustrate the significance of the

trade between the United States and Belgium.

On 27 November 2006, the United States and Belgium entered into a new

Double Tax Treaty that further reduces tax barriers to capital and labour mobility.

The Treaty provides, amongst other provisions, for the elimination of sour-ce-country

withholding taxes on qualifying dividends ; a much coveted provision

by US trading partners. Also, it includes a mandatory arbitration provision,

which applies to certain double taxation cases that cannot be resolved by the

competent authorities within a specified timeframe. It is currently one of only

three US tax treaties to include such a provision.

This book offers an in-depth analysis of the Treaty by high-profile Belgian and US

tax practitioners, all of whom have extensive experience in cross-border transactions

between the United States and Belgium. The book also discusses the many

opportunities offered by the Treaty and their practical applications, as well as certain

interpretative issues and how those can be resolved. In recognition of the growing

competition among jurisdictions for inbound investments, the authors have

also analysed how the Treaty compares with certain US tax treaties with other EU

Member States and how the EC Treaty affects the application of the Treaty.

Finally, this book also contains an introductory chapter highlighting how certain

US domestic tax rules may impact upon the application of the Treaty.

This book is a unique tool for any practitioner, lawyer or consultant faced with

an issue of cross-border investment, employment or other transactions between

the United States and Belgium.