India Belgium Double Taxation Avoidance Agreement 3. The imposition of a stable establishment that a company of a contracting state has in another contracting state is no less favourable to taxation in that other state than the imposition imposed on the business of that other state which carries out the same activities under the same circumstances and under the same conditions. 4. This agreement also applies to any identical or substantially similar tax levied in addition to or in place of existing taxes after the date of the signing of this agreement. The competent authorities of the State party communicate from time to time any substantial changes to their respective tax laws. 1. Legislation in one of the contracting states continues to govern the taxation and taxation of income in the contracting states concerned, unless this agreement expressly provides otherwise. Specific provisions apply to border workers in the following double taxation agreements: 2. The agreement between the Indian government and the Belgian government on the prevention of double taxation and the prevention of income tax evasion, signed on 7 February 1974, and the additional protocol amending this agreement and protocol, signed on 20 October 1984, will no longer come into force for income taxes covered in paragraph 1 of this article. 1. This agreement does not affect the tax privileges of diplomatic or consular officials under the general rules of international law or the provisions of specific agreements. with the intention of eliminating the double taxation of taxes covered by this agreement, without creating opportunities for non-taxation or reduced taxation by tax evasion or evasion (including through contractual shopping agreements to obtain indirect facilities for residents of third jurisdictions), 3. The competent authorities of the contracting states are working to resolve by mutual agreement any difficulties in implementing the convention.

They can also agree on the elimination of double taxation in cases not included in this agreement. (d) If, under Belgian law, the losses of a business operated by a company established in Belgium in a stable establishment in India were indeed deducted from the profits of that company for its taxation in Belgium, the exemption provided for in point (a) does not apply in Belgium to the profits of other taxable periods attributable to that establishment, as these profits have also been exempt from tax in India on the basis of compensation. The case must not be brought in accordance with the provisions of this agreement within three years of the first notification of the measure leading to taxation.