The US Internal Revenue Service (IRS) has released the official text of the recent competent authority agreement between the United States and Belgium. The agreement addresses the application of the principles set forth in the Organization for Economic Cooperation and Development (OECD) Report on the Attribution of Profits to Permanent Establishments (the "authorized OECD approach" or "full AOA") in the interpretation of article 7 (Business Profits) of the Belgium-United States Income Tax Treaty (2006). The authorized OECD approach applies the OECD Transfer Pricing Guidelines, by analogy, in determining the profits of a permanent establishment. The agreement was entered into under...