May 10, 2016
Ministry of Finance
Agreement in Principle on New Tax Convention with Belgium
[Provisional translation]
1. The Government of Japan and the Government of the Kingdom of Belgium have agreed in principle on a new Convention that replaces the Convention between Japan and the Kingdom of Belgium for the Avoidance of Double Taxation with respect to Taxes on Income which entered into force in 1970 as partially amended in 1990 and 2013.
2. The new Convention wholly amends the contents of the current Convention. The new Convention reduces taxation in the source country on investment income (dividends, interest and royalties), updates the Article concerning taxation on business profits, and introduces arbitration proceedings to the mutual agreement procedure to ensure settlement of disputes with respect to the Convention, with a view to further promoting investment and economic exchanges between the two countries. The new Convention also expands the cooperation between the tax authorities of the two countries by introducing an Article concerning assistance in the collection of taxes.
3. The new Convention will be signed after the necessary internal procedures have been completed by each of the two Governments. Thereafter, the new Convention will enter into force after the completion of the approval process on both sides (in the case of Japan, approval by the Diet is necessary).