The Belgian tax authorities on October 26 published a practice note (Ci.R9. Div. 607/317) clarifying the tax regime for employees working aboard dredgers.
The tax authorities note that in principle, dredging projects fall under articles 5 and 7 of Belgium’s tax treaties. This means their profits are taxable in the country where the enterprise is set up unless it has a permanent establishment in the country where it works. Only Belgium’s double tax agreements with Hong Kong and Macao list dredging projects as examples of projects that constitute a permanent establishment (read the full article).
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