Andy Cools, Arcalius, Opglabbeek, Belgium: Directors fees in an ...

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Article 16 OECD C. Remuneration Only such remuneration falls within the scope of the article as is paid in respect of the supervision of a company’s management. The remuneration may be paid in a fixed amount or as a share in the company’s profits or in both forms side by side. If however, the member of a board of directors is also a shareholder of the company concerned, it should be noted that any remuneration dependent on the profits made by the company might be considered to be distributions in respect of his interest in the company, i.e. dividends, at least under the law of some countries. Belgium – The Netherlands treaty: “werkende vennoten: article 15 or 16?
Article 16 OECD Other functions: a member of the board of directors of a company often also has other functions with the company, e.g. as ordinary employee, adviser, consultant, etc. It is clear that the article does not apply to remuneration paid to such a person on account of such other functions BUT: Belgium: force of attraction. Also in new double tax treaty with the Netherlands? Fictitious income? Only when permitted in context? Is a real payment necessary?
Page 1 and 2: Andy COOLS
Page 3 and 4: Article 16 OECD This article relate
Page 5 and 6: Article 16 OECD Some terms are not
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Andy Cools, Arcalius, Opglabbeek, Belgium: Directors fees in an ...

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