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ARTICLE 19

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

Governmental Functions

The existing Convention exempts compensation including pensions and annuities paid by one of the States or a political subdivision or territory thereof to a citizen of that State residing in the other State (whether or not also a citizen of the other State) from taxation by that other State. The proposed Convention continues the exemption but adds a specification that the compensation must be paid in connection with the discharge of functions of a governmental nature. Compensation paid in connection with industrial or commercial activity is treated the same as compensation received from a private employer. The provisions relating to dependent personal services, private pensions and annuities, and social security payments would apply in such a case.

The proposed Convention extends the category of individuals who are eligible for the exemption to citizens of a third State who come to a State expressly for the purpose of being

employed by the other State, a political subdivision, or a local authority thereof.

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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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