No Article 17 for Entertainers and Sportspersons in New Tax Treaty Belgium - The Netherlands

Abstract

There is no Article 17 for entertainers and sportspersons in the 2023 new tax treaty between Belgium and the Netherlands. They decided not to follow the OECD recommendation, because the article creates too much administrative expenses. Use of the normal allocation articles for companies, self-employed and employees are well equipped for these two special types of taxpayers when they perform in the other state. The authors compare this to the OECD, UN and US Model Tax Conventions. They conclude that the risk of double or excessive taxation is much lower without an Article 17 in a bilateral tax treaty between states with a normal tax system.

Keywords: Tax; Entertainers; Sportspersons; Tax Treaties; Belgium; Netherlands

JEL Classification: K34