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### Synthesised text of the MLI and the convention between the Government of the Kingdom of Belgium and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, signed at Brussels on 1 June 1987, as amended by the protocol signed at Paris on 24 June 2009
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This document was prepared in consultation with the competent authority of the United Kingdom and represents our shared understanding of the modifications made to the Convention by the MLI.
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General disclaimer on the synthesised text document.
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This document presents the synthesised text for the application of the Convention between the Government of the Kingdom of Belgium and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains signed on 1 June 1987 and the Protocol signed on 24 June 2009 (together the ‘Convention’), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by Belgium and the United Kingdom on 7 June 2017 (the ‘MLI’).
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The document was prepared on the basis of the MLI position of Belgium submitted to the Depositary upon ratification on 26 June 2019 and of the MLI position of the United Kingdom submitted to the Depositary upon ratification on 29 June 2018. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of the MLI on this Convention.
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The authentic legal texts of the Convention and the MLI take precedence and remain the legal texts applicable.
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The provisions of the MLI that are applicable with respect to the provisions of the Convention are included in boxes throughout the text of this document in the context of the relevant provisions of the Convention. The boxes containing the provisions of the MLI have generally been inserted in accordance with the ordering of the provisions of the OECD Model Tax Convention.
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Changes to the text of the provisions of the MLI have been made to conform the terminology used in the MLI to the terminology used in the Convention (such as ‘Covered Tax Agreement’ and ‘Convention’, ‘Contracting Jurisdictions’ and ‘Contracting States’), to ease the comprehension of the provisions of the MLI. The changes in terminology are intended to increase the readability of the document and are not intended to change the substance of the provisions of the MLI. Similarly, changes have been made to parts of provisions of the MLI that describe existing provisions of the Convention: descriptive language has been replaced by legal references of the existing provisions to ease the readability.
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In all cases, references made to the provisions of the Convention or to the Convention must be understood as referring to the Convention as modified by the provisions of the MLI, provided such provisions of the MLI have taken effect.