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(e) SALARIES AND WAGES

Normally, remuneration paid in Belgium, including the fees of directors of share companies, is subject to deduction of professional tax at source; further, remuneration received abroad by a person domiciled or resident in Belgium is liable to professional tax on the basis of an annual declaration. The tax, however — which is fixed by the Belgian commune where the taxpayer is domiciled or resident — is computed at a reduced rate if the income is earned and taxed abroad.

The Conventions lay it down as a rule that the fees of company directors and of others discharging similar functions are taxable in the State in which the enterprise has its real head office.

The various payments to salaried workers and wage-earners are taxed in the country in which the taxpayer is working.

The salaries of the public servants of one country who exercise their functions in the other are taxed only in the country which pays them.

Finally, public and private pensions are taxed in the country which owes this income, annuities in the country in which the recipient has his fiscal domicile.

Accordingly, tax will in future be collected, in respect of the income mentioned above, by one State only: in the case of directors, etc., of share companies, by the country in which the enterprise has its real head office; in the case of salaried workers and wage-earners, by the country where they do their work; in the case of public servants, by the country which pays them; in the case of pensions, by the country which owes them and, in the case of annuities, by the country in which the recipient has his fiscal domicile.

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