The present note has not for purpose to give an answer to all the questions raised by foreign EEC interim companies who put people during short, middle or long term periods at the disposal of Belgian companies in the context of "services agreements". Generally these people are IT specialists and enjoy the benefits of the 1.408/71 EEC ruling meaning they stay under the umbrella of the social security of the foreign employer.
As regards secondments of expatriates to Belgium we frequently find the situation where the executive continue to be paid by the foreign company which seconds him near the Belgian company (within the framework of a provision of personnel) and curiously when on the basis of a net take home pay basis where taxes are paid by the Belgian company.
In this context I raise three questions:
17 February 2016
"WASHINGTON - Today, the Treasury Department issued a newly revised U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax treaties. The U.S. Model Income Tax Convention was last updated in 2006". (Press Release U.S Department of Treasury).