A revised Double Tax Treaty between Belgium and Romania has recently been ratified by the Romanian Parliament and likely to come into place early next year.

The features of this treaty include the following withholding tax rates:

1. Royalty withholding tax - 5%
2. Interest withholding tax - 10%
3. Dividend withholding tax 5% if paid to a shareholder with more than 25% shareholding (15% otherwise)

The treaty also has the following provisions that are likely to be introduced in all future treaties:

1. The 183 days rule for individual taxation has been extended to 183 days in any twelve month period (not calendar year). This provision conforms to the relevant provision in Romanian domestic legislation.

2. A mutual assistance for collection. This unique provision will allow one of the countries, (at the request of the competent authorities from the other country) to collect the taxes owed in the first country.

The above information is a short summary of recently published information and is not intended to advise on any particular matter. Price Waterhouse expressly disclaims any responsibility to any person in respect of anything done in reliance of the contents of these publications.

Further information can be obtained from:

Ron Barden or Anca Troaca-Dragoman
Price Waterhouse Romania
Union International Center
11 Campineanu Street
Sector 1 Bucharest Romania

Telephone: 40-1-311-2455
Telefax: 40-1-312-3334

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