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Article 5 provides that the Protocol, as an integral part of the 1970 Convention, shall

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

remain in force as long as the 1970 Convention remains in force and shall terminate simultaneously with that Convention. A special rule, however, permits separate termination of the Protocol after it has been in force for five years if either State gives Six months' notice of termination in writing through diplomatic channels. In such a case, the provisions of the Protocol would cease to have effect for amounts paid or credited on or after the first day of January of the year following the notice of termination, and the provisions of the 1970 Convention, as it applied prior to amendment by the Protocol, shall have effect with respect to such amounts. This special rule is included, not because of any anticipated dissatisfaction with the operation of the Protocol, but as an indication of the intent of both sides to complete renegotiation of a full new treaty as promptly as feasible.

EXCHANGE OF NOTES

An exchange of notes, signed at the same time as the Protocol, confirms the understanding of the two delegations that the term beneficial interest', as used in paragraph 1(a)(i) of Article 12A (Limitation on Benefits) of the English text of the Protocol has the same meaning in the French and Dutch texts of the Corresponding provision, notwithstanding any imprecision in the translations of that phrase.

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