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ARTICLE 1

U.S. Income Tax Treaty — belgium tax treaty documents: belgtech.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Personal Scope

This Article, which is not found in other United States tax treaties, is similar to Article 1 of the Draft Double Taxation Convention on Income and Capital developed by the Fiscal Committee of the Organization for Economic Cooperation and Development and published in 1963 (hereinafter referred to as the OECD Model Convention). The Article does not have substantive importance. Its purpose is to generally delineate the persons who come within the scope of the Convention. The Article is not complete in its delineation of persons covered in that persons who are residents of one or both of the Contracting States are sometimes not covered in the Convention and that other persons who are not residents of either of the Contracting States are covered by this Convention. For example, Article 19 (Governmental Functions) applies to citizens of a third State who come to one of the Contracting States expressly for the purpose of being employed by the other Contracting State. While the title of Article 1 is “Personal Scope,” the Convention, of course, is applicable to corporations and other entities as well as to individuals.

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▸Contents — U.S. Income Tax Treaty — belgium tax treaty documents: belgtech.pdf
U.S. Income Tax Treaty — belgium tax treaty documents: belgtech.pdf

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