OrbitaxTreaty between Belgium and France – Court of Appeal of Brussels decides compensation received per non-competition clause classified as employment income
|Treaty Development|Belgium-France
On 20 September 2007, the Court of Appeal of Brussels decided a case on the classification under the Belgium-France tax treaty on income and capital of 10 March 1994 (the "treaty") of a compensation received pursuant to a non-competition clause in an employment agreement. Details of the case are described below.
(a) Facts. The taxpayer was a Belgian resident. On 1…
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