Belgium - Uruguay Tax Treaty

Republica ©siontal del Uruguay

CONVENTION BETWEEN THE ORIENTAL REPUBLIC OF URUGUAY AND THE KINGDOM OF BELGIUM FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

AND FOR THE PREVENTION OF FISCAL EVASION

Repiiblica Oriental del Unuguay

CONVENTION BETWEEN THE ORIENTAL REPUBLIC OF URUGUAY AND THE KINGDOM OF BELGIUM FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL AND FOR THE PREVENTION OF FISCAL EVASION

THE ORIENTAL REPUBLIC OF URUGUAY,

on the one hand, AND

THE KINGDOM OF BELGIUM,

THE FLEMISH COMMUNITY,

THE FRENCH COMMUNITY,

THE GERMAN-SPEAKING COMMUNITY, THE FLEMISH REGION,

THE WALLOON REGION, and THE BRUSSELS-CAPITAL REGION,

on the other hand,

DESIRING to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital and for the prevention of fiscal evasion,

HAVE AGREED as follows:

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CHAPTER I. —- SCOPE OF THE CONVENTION Article I Persons covered

eae Convention shall apply to persons who are residents of one or both of the Contracting tates.

Article 2

Taxes covered

=‘ This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

The existing taxes to which the Convention shall apply are in particular:

a) _ in the case of Belgium:

(i) the individual income tax;

(ii) the corporate income tax;

(iii) the income tax on legal entities;

(iv) _ the income tax on non-residents;

including the prepayments and the surcharges on these taxes and prepayments,

(hereinafter referred to as “Belgian tax”);

b) in the case of Uruguay:

(i) the tax on business income (Impuesto a las Rentas de Jas Actividades

Econémicas - IRAE); (ii) the personal income tax (Impuesto a las Rentas de las Personas Fisicas - IRPF); (iii) the non-residents income tax (Impuesto a las Rentas de los No Residentes - JRNR); ; ; (iv) the tax for social security assistance (Impuesto de Asistencia a la Seguridad Social - [ASS); and ; (v) _ the capital tax (Impuesto al Patrimonio - IP);

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(hereinafter referred to as “Uruguayan tax”).

The Convention shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Convention in addition to, or in place of, the

existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.

CHAPTER II. —- DEFINITIONS Article 3

General definitions

For the purposes of this Convention, unless the context otherwise requires:

a) the term “Belgium” means the Kingdom of Belgium; used in a geographical sense, it means the territory of the Kingdom of Belgium, including the territorial sea and any other area in the sea and in the air within which the Kingdom of Belgium, in accordance with international law, exercises sovereign rights or its jurisdiction;

b) the term “Uruguay” means the territory of the Oriental Republic of Uruguay, and when used in a geographical sense means the territory on which the tax laws are applied, including the airspace, the maritime areas, under Uruguayan sovereign rights or jurisdiction in accordance with international law and national law;

c) the terms “a Contracting State” and “the other Contracting State” means Belgium or Uruguay as the context requires;

d) the term “tax” means Belgian or Uruguayan tax, as the context requires;

e) the term “person” includes an individual, a company and any other body of persons;

f) the term “company” means any body corporate or any entity that is treated as a body corporate for tax purposes;

g) the term “enterprise” applies to the carrying on of any business;

h) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a

Contracting State and an enterprise éarried on by a resident of the other Contracting

State;

i) the term “international traffic’? means any transport by a ship or aircraft operate’ Py an enterprise that has its place of effective management in a Contracting State,

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except when the ship or aircraft is operated solely between places in the other

Contracting State;

the term “competent authority” means:

(i) in the case of Belgium, as the case may be, the Minister of Finance of the Federal Government and/or of a Region and/or of a Community, or his authorised representative; and

(ii) in the case of Uruguay, the Minister of Economy and Finance or his authorized representative;

the term “national”, in relation to a Contracting State, means:

(i) amy individual possessing the nationality or citizenship of that Contracting State; and

(ii) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State;

the term “business” includes the performance of professional services and of other

activities of an independent character;

the term “pension fund” means any person established in a Contracting State:

(i) _ that administers pension schemes or provides retirement benefits; or (il) _ that ears income on behalf of one or more persons operated to administer pension schemes or provide retirement benefits; and

provided it is either:

(i) in the case of Belgium, regulated by the Financial Services and Markets Authority (FSMA) or by the National Bank of Belgium, or registered with the Belgian tax Administration; or

(ii) in the case of Uruguay, the Banco de Previsién Social, the pension funds (Administradoras de Fondos de Ahorro Previsional - AFAP) and the insurance entities, regulated by Law 16.713 and other social security entities

regulated by Uruguayan laws.

As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.

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Article 4 Resident

For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.

Where by reason of the provisions of paragraph | an individual is a resident of both

Contracting States, then his status shall be determined as follows:

a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests);

b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode;

c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national;

d) ifhe is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

Where by reason of the provisions of paragraph | a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.

Article 5 Permanent establishment

For the purposes of this Convention, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried

on.

The term “permanent establishment” includes especially:

a) aplace of management, b) — a branch; c) an office;

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d) a factory; e) — aworkshop, and

f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources,

The term “permanent establishment” likewise includes:

a) a building site or a construction or installation project, but only if such site or project lasts more than 6 months;

b) the furnishing of services ina Contracting State, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for Such purpose, but only where these employees or personnel are present in that Contracting State (for the same or a connected project) for a period or periods aggregating more than six months within any twelve-month period.

Notwithstanding the preceding provisions of this Article, the term “permanent

establishment” shall be deemed not to include:

a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise;

b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery;

c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;

d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise;

e) the maintenance ofa fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;

f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs a) to e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.

Notwithstanding the provisions of paragraphs | and 2, where a person -other than an agent of an independent status to whom paragraph 6 applies- is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude coniracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to hose mentioned in paragraph 4 which, if exercised through a fixed place of business, woul . not make this fixed place of business a permanent establishment under the provisions of tha’

paragraph.

An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general

commission agent or any other agent of an independent status, provided that such persons

are acting in the ordinary course of their business.

The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

CHAPTER Hil. - TAXATION OF INCOME

Article 6 Income from immovable property

Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. The term “immovable property” shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise.

Article 7

Business profits

The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as are attributable to that permanent establishment.

Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the protits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently.

In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment,

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including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

Where, in accordance with paragraph 2, a Contracting State adjusts the profits that are attributable to a permanent establishment of an enterprise of one of the Contracting States and taxes accordingly profits of the enterprise that have been charged to tax in the other State, then that other State shall, to the extent necessary to eliminate double taxation on these profits, make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, the competent authorities of the Contracting States shall if necessary consult each other. This provision shall not apply in cases where one or more transactions leading to an adjustment of profits are regarded as fraudulent according to an administrative or judicial decision.

Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.

No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

Where profits include items of income which are dealt with separately in other Articles of the Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

Article 8 Shipping and air transport

Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

For the purpose of this Article, profits from the operation of ships or aircraft in international traffic shall include in particular:

a) profits from the leasing of ships or aircraft engaged in international traffic on charter fully equipped, manned and supplied;

b) profits from the leasing of ships or aircraft on a bare boat charter basis if such leasing activity is an ancillary activity for the enterprise engaged in international traffic;

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c) profits from the leasing of containers if such leasing activity is an ancillary activity for the enterprise engaged in international traffic.

If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.

The provisions of paragraph | shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

Article 9

Associated enterprises Where: / . a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, _ may be included in the profits of that enterprise and taxed accordingly. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Convention and the competent authorities of the Contracting States shall if necessary consult each other.

The provisions of paragraph 2 shall not apply in cases where one or more transactions leading to an adjustment of profits in accordance with paragraph | are regarded as fraudulent according to an administrative or judicial decision.

Article 10

Dividends

Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State,

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However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:

a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends;

b) 15 per cent of the gross amount of the dividends in all other cases. Notwithstanding the preceding provisions of this paragraph, dividends shall not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a pension fund that is a resident of the other Contracting State, provided that the shares or other rights in respect of which such dividends are paid are held for the purpose of an activity mentioned under Article 3, paragraph |, m). This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends. are paid. The term “dividends” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits, as well as income which is subjected to the same taxation treatment as income from shares by the tax laws of the State of which the paying company is a resident. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident through a permanent establishment situated therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company’s undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Article 11

Interest

Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

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However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. Notwithstanding the provisions of paragraph 2, interest shall be exempted from tax in the Contracting State in which it arises if it is: a) interest paid to a pension fund, provided that the debt-claim in respect of which such interest is paid is held for the purpose of an activity mentioned under Article 3, paragraph 1, m); b) interest paid to the other Contracting State, to one of its political subdivisions or local authorities or to a public entity. The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. However, the term “interest” shall not include, for the purpose of this Article, penalty charges for late payment nor interests regarded as dividends under paragraph 3 of Article 10, The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.

Article 12

Royalties

Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties.

The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.

In case of royalties for the use of, or the right to use, industrial, commercial or scientific equipment, derived by a resident of a Contracting State from the other Contracting State, such resident may elect to be taxed on a net basis as if he were a resident of the other Contracting State. This election may be exercised after the application of the withholding tax described in paragraph 2, on the gross amount.

The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. ‘

Royalties shail be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated.

Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.

Article 13 Capital gains Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed

in that other State.

Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other

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Contracting State, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other State.

Gains from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State. However, this paragraph shall not apply to gains derived from the alienation of shares of companies that are listed on an approved stock exchange of one of the Contracting States, to gains derived from the alienation of shares in the course of a merger or division of the company holding the shares, or where the immovable property from which the shares derive their value is immovable property in which an active trade or business is carried on.

Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator is a resident.

Article 14 Income from employment

Subject to the provisions of Articles 15, 17 and 18, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is.so exercised, such remuneration as is derived therefrom may be taxed in that other State.

Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a

Contracting State in respect of an employment exercised in the other Contracting State

shall be taxable only in the first-mentioned State if:

a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period concerned, and

b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and ,

c) the remuneration is not borne by a permanent establishment which the employer has in the other State.

Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the Contracting State in which the place of effective management of the . enterprise is situated. ‘ 1s>)

Republica Oriented del Uruguay

Article 15 Directors’ fees

Directors’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.

Remuneration derived by a person referred to in paragraph 1 from a company which is a resident of a Contracting State in respect of the discharge of day-to-day functions of a managerial or technical, commercial or financial nature and remuneration received by a resident of a Contracting State in respect of his day-to-day activity as a partner of a company, other than a company with share capital, which is a resident of a Contracting State, shall be taxable in accordance with the provisions of Article 14, as if such remuneration were remuneration derived by an employee in respect of an employment and as if references to the “employer” were references to the company.

Article 16 Artistes and sportsmen

Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.

Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

The provisions of paragraphs 1 and 2 shall not apply if the activities exercised in a Contracting State are substantially supported from public funds of the other Contracting State or a political subdivision or a local authority thereof. In such case, income derived from such activities shall be taxable only in that other Contracting State.

Article 17

Pensions

Subject to the provisions of paragraph 2 of Article 18, pensions and other similar remuneration paid to a resident of a Contracting State shall be taxable only in that State.

Such pensions and other similar remuneration may also be taxed in the Contracting State in which they arise and according to the laws of that State. However, the tax so charged shall not exceed 10 per cent of the gross amount of the payment.

Pensions and other similar remuneration shall be deemed to arise in a Contracting State to the extent that the contributions to a pension scheme have given rise in that State to tax deduction, reduction of tax or any other tax relief.

Article 18 Government service

a) Salaries, wages and other similar remuneration paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.

b) — However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who:

(i) _ is anational of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services.

a) Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.

b) | However, such pension and other similar remuneration shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

The provisions of Articles 14, 15, 16 and 17 shall apply to salaries, wages, pensions and

other similar remuneration in respect of services rendered in connection with a business

carried on by a Contracting State or a political subdivision or a local authority thereof.

Article 19

Students

Payments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first- mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.

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Article 20 Other income

Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.

The provisions of paragraph | shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein and the right or property in respect of which the income is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing articles of the Convention and arising in the other Contracting State may be taxed in that other State if such items of income are not effectively taxed in the first-mentioned State.

CHAPTER IV. — TAXATION OF CAPITAL Article 21 Capital

Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.

Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State.

Capital represented by ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

CHAPTER V. — METHODS FOR ELIMINATION OF DOUBLE TAXATION Article 22

Elimination of double taxation

In the case of Belgium:

a) Where a resident of Belgium derives income, not being dividends, interest or royalties, or owns elements of capital which are taxed in Uruguay in accordance with the provisions of this Convention, Belgium shall exempt such income or such elements of capital from tax. Notwithstanding the preceding provision, where an individual derives income, not being dividends, interest or royalties, which are taxed in Uruguay in accordance with the provisions of the Convention, Belgium shall only exempt such income from tax to the extent that such income is effectively taxed in Uruguay.

b) The exemption provided for in subparagraph a) shall also be granted with respect to income regarded as dividends under Belgian law, which is derived by a resident of Belgium from a participation in an entity that has its place of effective management in Uruguay, and has not been taxed as such in Uruguay, provided that the resident of Belgium has been taxed in Uruguay, proportionally to his participation in such entity, on the income out of which the income regarded as dividends under Belgian law is paid. The exempted income is the income received after deduction of the costs incurred in Belgium or elsewhere in relation to the management of the participation in the entity.

c) Notwithstanding the provisions of subparagraphs a) and b) and any other provision of the Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels — beroepsinkomsten) that is exempted from tax in Belgium in accordance with subparagraphs a) and b). These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources.

Where in accordance with any provision of the Convention income derived or capital owned by a resident of Belgium is exempted from tax in Belgium, Belgium may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted.

d) The provisions of subparagraphs a) and b) shall not apply to income derived or capital owned by a resident of Belgium where Uruguay applies the provisions of the Convention to exempt such income or capital from tax or applies the provisions of paragraph 2 of Article 10 or paragraph 2 of Article 11 to limit the taxation of such income.

| Repusblion Oriental del Usuguay

Dividends derived by a company which is a resident of Belgium from a company which is a resident of Uruguay shall be exempted from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. Where a company which is a resident of Belgium derives from a company which is a resident of Uruguay dividends which are not exempted in accordance with subparagraph e), such dividends shall nevertheless be exempted from the corporate income tax in Belgium if the company which is a resident of Uruguay is effectively engaged in the active conduct of a business in Uruguay. In such case, such dividends are exempted under the conditions and within the limits provided for in Belgian law except those related to the fiscal regime applicable to the company which is a resident of Uruguay or to the income out of which the dividends are paid. This provision shall only apply to dividends paid out of income generated by the active conduct of a business.

Where a company which is a resident of Belgium derives from a company which is a resident of Uruguay dividends which are included in its aggregate income for Belgian tax purposes and which are not exempted from the corporate income tax according to subparagraphs e) or f), Belgium shall deduct from the Belgian tax relating to these dividends, the Uruguayan tax levied on these dividends in accordance with Article 10 and the Uruguayan tax levied on the profits out of which these dividends are paid. This deduction shall not exceed that part of the Belgian tax which is proportionally relating to these dividends.

Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the Uruguayan tax levied on that income shall be allowed as a credit against Belgian tax relating to such income.

Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Uruguay have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the. exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in Uruguay by reason of compensation for the said losses.

In Uruguay, double taxation shall be eliminated as follows:

Residents of Uruguay, deriving income, not being dividends, which has, in accordance with Belgian law and under the provisions of this Convention, been subject to taxation in Belgium, may credit the tax so paid against any Uruguayan tax payable in respect of the same income, subject to the applicable provisions of the law of Uruguay. The same shall also apply in respect of capital which has, in accordance with Belgian law and under the provisions of this Convention, been subject to taxation in Belgium; the capital tax so paid may be credited against any Uruguayan tax payable in respect of the same capital, subject to the applicable

provisions of the law of Uruguay. Such deduction shall not, however, exceed that part of the Uruguayan tax on income or capital, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Belgium.

b) Where a company which is a resident of Uruguay derives from a company which is a resident of Belgium dividends which are included in its taxable income for Uruguayan tax purposes, Uruguay shali deduct from the Uruguayan tax relating to these dividends, the Belgian tax levied on these dividends in accordance with Article 10 and the Belgian tax Jevied on the profits out of which these dividends are paid. This deduction shall not exceed that part of the Uruguayan tax which is proportionally relating to these dividends.

c) Where, in accordance with any provision of the Convention, income derived or capital owned by a resident of Uruguay is exempt from tax in Uruguay, Uruguay may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.

CHAPTER VI. — SPECIAL PROVISIONS Article 23 Non-discrimination

Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States.

Stateless persons who are residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of the State concerned in the same circumstances, in particular with respect to residence, are or may be subjected.

The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 7 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the

ive)

Republica Oriental del Usuguay

purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a-resident of the first-mentioned State. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State.

Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description.

Article 24 Mutual agreement procedure

Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.

The competent authorities of the Contracting States shall endeavour to resolve by mutual

agreement any difficulties or doubts arising as to the interpretation or application of the

Convention.

The competent authorities of the Contracting States may: communicate with each other

directly, including through a joint commission consisting of themselves or their

representatives, for the purpose of reaching an agreement in the sense of. the preceding

paragraphs or for the application of this Convention.

Where, . oo, .

a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting

States have resulted for that person in taxation not in accordance with the provisions of the Convention, and

b) the competent authorities are unable to reach an agreement to resolve that case pursuant to paragraph 2 within two years from the presentation of the case to the competent authority of the other Contracting State, any unresolved issues arising from the case shall be submitted to arbitration if the person so requests within two years from the first day from which arbitration may be requested. These unresolved issues shall not, however, be submitted to arbitration if a decision on. these issues has already been rendered by a court or administrative tribunal of either Contracting State. Unless a person directly affected by the case informs the competent authority of a Contracting State, within three months from the communication of the mutual agreement that implements the arbitration decision, that he does not accept the mutual agreement, the arbitration decision shall be binding and shail be implemented notwithstanding any time limits in the domestic laws of both Contracting States. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this paragraph.

Article 25 — Exchange of information

The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Articles 1 and 2.

Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.

In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:

a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;

b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;

c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation. contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.

In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, trust, foundation, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.

Article 26 Assistance in the collection of taxes

The Contracting States shall lend assistance to each other in the collection of revenue claims. This assistance is not restricted by Article {. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Article.

The term “revenue claim” as used in this Article means any amount owed in respect of taxes covered by the Convention, together with interest, administrative penalties and costs of collection or conservancy related to such amount.

When a revenue claim of a Contracting State is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, that revenue claim shall, at the request of the competent authority of that State, be accepted for purposes of collection by the competent authority of the other Contracting State. That revenue claim shall be collected by that other State in accordance with the provisions of its laws applicable to the enforcement and collection of its own taxes as if the revenue claim were a revenue claim of that other State.

When a revenue claim of a Contracting State is a claim in respect of which that State may, under its law, take measures of conservancy with a view to ensure its collection, that revenue claim shali, at the request of the competent authority of that State, be accepted for purposes of taking measures of conservancy by the competent authority of the other Contracting State. That other State shall take measures of conservancy in respect of that revenue claim in accordance with the provisions of its laws as if the revenue claim were a revenue claim of that other State even if, at the time when such measures are applied, the revenue claim is not enforceable in the first-mentioned State or is owed by a person who

has a right to prevent its collection.

Rpalce Crt ed Maguay

Notwithstanding: the provisions of paragraphs 3 and 4, a revenue claim accepted by a Contracting State for purposes of paragraph 3 or 4 shall not, in that State, be subject to the time limits or accorded any priority applicable to a revenue claim under the laws of that State by reason of its nature as such. In addition, a revenue claim accepted by a Contracting State for the purposes of paragraph 3 or 4 shail not, in that State, have any priority applicable to that revenue claim under the laws of the other Contracting State.

Proceedings with respect to the existence, validity or amount of a revenue claim of a Contracting State shall not be brought before the courts or administrative bodies of the other Contracting State.

Where, at any time after a request has been made by a Contracting State under paragraph 3 or 4 and before the other Contracting State has collected and remitted the relevant revenue claim to the first-mentioned State, the relevant revenue claim ceases to be

a) in the case of a request under paragraph 3, a revenue claim of the first-mentioned State that is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, or

b) in the case of a request under paragraph 4, a revenue claim of the first-mentioned State in respect of which that State may, under its laws, take measures of conservancy with a view to ensure its collection, the competent authority of the first-mentioned State shail promptly notify the competent authority of the other State of that fact and, at the option of the other State, the first-mentioned State shall either suspend or withdraw its request.

In no case shall the provisions of this Article be construed so as to impose on a

Contracting State the obligation:

a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;

b) to carry out measures which would be contrary to public policy (ordre public);

c) to provide assistance if the other Contracting State has not pursued all reasonable measures of collection or conservancy, as the case may be, available under its laws

or administrative practice;

d) to provide assistance in those cases where the administrative burden for that State is clearly disproportionate to the benefit to be derived by the other Contracting

State, Article 27

Members of diplomatic missions and consular posts

Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special

agreements.

CHAPTER VII. — FINAL PROVISIONS

Article 28

Entry into force

| The Governments of the Contracting States shall notify each other that the constitutional requirements for the entry into force of this Convention have been complied with.
The Convention shail enter into force on the fifteenth day after the date of the later of the notifications referred to in paragraph 1 and its provisions shall have effect:

in respect, of taxes due at source, for amounts credited or payable on or after the first day of January in the first calendar year following that in which this Convention enters into force;

in respect of other income taxes, for the taxable periods beginning on or after the first day of January in the first calendar year following that in which this Convention enters into force; and

in respect of any other taxes, in respect of taxes due in respect of taxable events taking place on or after the first day of January in the first calendar year following that in which this Convention enters into force.

Article 29

Termination

This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving to the other Contracting State, written notice of termination not later than the 30th June of any calendar year from the fifth year following that in which the Convention entered into force. In the event of termination before July 1 of such year, the Convention shall cease to have effect:

a) b)

¢)

in respect of taxes due at source, for amounts credited or payable on or after the first day of January in the first calendar year following that in which the notice is

given;

in respect of other income taxes, for the taxable periods beginning on or after the first day of January in the first calendar year following that in which the notice is given; and :

with respect to any other taxes, in respect of taxes due in respect of taxable events taking place on or after January 1 of the year next following the year in which the notice of termination is given.

IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Convention.

DONE in duplicate at Mouteu ato evens on the R38 say of aster. bees

2013, in Spanish, French, Dutch and English languages, all four texts being equafly authentic. In case of divergence between the texts, the English text shall prevail.

D oa (at

FOR THE ORIENTAL REPUBLIC FOR THE KINGDOM OF BELGIUM: ; FOR THE FLEMISH COMMUNITY: FOR THE FRENCH COMMUNITY:

FOR THE GERMAN-SPEAKING COMMUNITY:

FOR THE FLEMISH REGION:

FOR THE WALLOON REGION: FOR THE BRUSSELS-CAPITAL REGION:

Repetblica Oriental del Upuguay

PROTOCOL

At the moment of signing the Convention between the Oriental Republic of Uruguay and the Kingdom of Belgium for the avoidance of double taxation with respect to taxes on income and on capital and for the prevention of fiscal evasion, the undersigned have agreed upon the following provisions which shall form an integral part of the Convention.

Notwithstanding the provisions of any Article of the Convention, no reduction in or exemption from tax provided for in the Convention shall be applied to income paid in connection with a wholly artificial arrangement. An arrangement shall not be considered as wholly artificial where evidence is produced that the arrangement reflects economic reality.

Ad Article 4, paragraph |:

It is understood that a person is “liable to tax” in a Contracting State where that person is subjected to the tax laws in force in that Contracting State even if, according to those laws, all or part of its income or capital is exempted from tax.

It is understood that the term “resident of a Contracting State” includes a pension fund established in that State. ,

Ad Articles 10, 11 and 12:

If after signing this Convention, one of the Contracting States signs with another State

that is a member of the European Union, a Convention that provides for lower rates of

taxation or other exemptions than those provided for in Articles 10, 11 or 12 of this

Convention, the competent authorities of the Contracting States shall on request consult

with each other.

Ad Article 13, paragraph 4:

The terms “merger” and “division” shall have the meaning that these terms have:

a) in the case of Belgium, in Council Directive 90/434/EEC of 23 July 1990 on the common system of taxation applicable to mergers, divisions, transfers of assets and exchanges of shares concerning companies of different member States;

b) in the case of Uruguay, in Law 16.060 of 4 September 1989.

Ad Articles 14 and 15:

It is understood that a compensation paid by reason of the termination of an employment, or of a mandate in a company, may be taxed in the Contracting State in which the employment is exercised, or of which the company is a resident, if and to the extent that the salaries or fees derived during the calendar year preceding the termination of that employment or mandate in respect of that employment or mandate may be taxed in that State according to the provisions of Article 14 or Article 15, as the case may be.

Ad Article 17, paragraph 2:

In the case of Jump sum pension contracts the limitation of the tax to 10 per cent in a Contracting State shall apply if the recipient is a resident of the other Contracting State

and has complied with the residence condition as a pensioner in such other Contracting State, for an uninterrupted period of at least five years on the date of his claim. Having fulfilled the above condition, the recipient may make the corresponding claim.

Ad Article 20, paragraph 3 and Article 22, paragraph 1, a):

For the application of paragraph 3 of Article 20 and paragraph 1, a) of Article 22, an item of income is effectively taxed in a Contracting State where such item of income is subjected to tax in that Contracting State and does not benefit as such from an exemption from tax therein.

Ad Article 22, paragraph 1, a), b) and f):

a) For the application of paragraph 1, a) and b) of Article 22, an item of income is “taxed” in Uruguay in particular where such item of income is subjected in Uruguay to one or more of the following regimes (as these regimes may change from time to time without modifying their substance):

(i) Decree - Law 14.335 of 23 December 1974 - Tourism Promotion Law;

(ii) Law 15.921 of 17 December 1987 - Free Zones Law;

(iii) Law 15.939 of 28 December 1987 - Forestry Law;

(iv) Article 92 of Law 16.002 of 25 November 1988 - Citrus Plantation Benefits; (v) Law 16.906 of 7 January 1998 - Investments Promotion Law; and

(vi) Article 52 Title 4 Texto Ordenado 1996, Law 18.083 of 27 December 2006 - Biotechnology and Software Benefits.

This provision shall apply to profits of companies only if such profits are derived from the active conduct of a business in Uruguay.

b) Paragraph 1, a) and f) of Article 22 shall apply to income or dividends paid out of profits derived in Uruguay from financial, holding or services activities (including services activities dealt with under a) (ii) above), where such income or profits are exempted from tax in Uruguay, only if such income or profits do not include items that have been deducted from income or profits that are taxable in Belgium.

After a period of ten years following the entry into force of this Convention, the competent authorities shall evaluate this provision, and if necessary, the Contracting States shall enter into negotiations to revise its scope.

Repthlica Oriental del Uruguay

IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol.

DONE in duplicate at If OM OMbtMded kates on the ..%.. ey of . AasPhdcac ng equally authentic.

2013, in Spanish, French, Dutch and English languages, ail four texts bei In case of divergence between the texts, the English text shall prevail.

FOR THE KINGDOM OF BELGIUM: FOR THE FLEMISH COMMUNITY: FOR THE FRENCH COMMUNITY:

FOR THE GERMAN-SPEAKING COMMUNITY:

FOR THE FLEMISH REGION:

FOR THE WALLOON REGION: FOR THE BRUSSELS-CAPITAL REGION:

FOR THE ORIENTAL REPUBLIC

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