On 19 February 2013, the Belgian administration published a clarifying circular (No. 3/203 (AFZ/097-0380) of February 2013) on the Belgium - United States Income Tax Treaty (2006) (the Treaty). The most important details of the circular are summarized below.

(a) Business profits derived by hybrid entities

Articles 1(6) and 3(1)(c) of the Treaty provide that hybrid entities are …