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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Belgium: source of income

For the purposes of the Elimination of double taxation Article, income, profits or capital gains owned by a resident of the United Kingdom which can be taxed in Belgium under the provisions of the Convention are deemed to have a source in Belgium (Article 23(3) of the agreement). Interest and royalties are deemed to arise in the country in which the payer is resident (Articles 11(6) and 12(5).