Belgium Clarifies Tax Treatment of Dredge Workers
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 Macao1 list dredging projects as examples of projects that constitute a PE.
Guidance Clarifies Tax Treatment of Dredge Workers, Tax Notes International, 8 November 2010, p. 399