Details of the income tax treaty and protocol between Belgium and the Isle of Man, signed on 16 July 2009, have become available. The treaty was signed in the English language. The treaty generally follows the OECD Model Convention (2008). The maximum rates of withholding tax are: -   15% on dividends. However, the rate is 0% if (i) the receiving company owns directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of at least 12 months; or (ii) dividends are derived by a pension fund, if such dividends are not derived...