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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Belgium: interest

Article 11(2) of the agreement provides that Belgian tax on interest arising in Belgium to a United Kingdom resident will be reduced to:

  • 0% on interest paid on any loan granted or credit extended from one enterprise to another enterprise;
  • 0% on interest paid to a pension scheme established in the United Kingdom;
  • 0% on interest paid to the United Kingdom Government, a political subdivision thereof, a local authority or any public entity;
  • 10% in all other cases.

The EC Directive on Interest and Royalties (2003/49EC) (see INTM400010 to INTM400110) provides for the abolition of source state taxation on interest and royalty payments made between associated companies in different Member States.