I think I found the relevant document !!
http://www.fisconet.fgov.be/nl/?bron...ame=hok0@HOK30&
Number Hok8
HONG KONG (Treaty of 10.12.2003)
Article 8 Shipping and air transport
1. Profits derived from the operation of ships or aircraft in international traffic by an enterprise of a Contracting Party shall be taxable only in that Party.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purpose of this Article, profits from the operation in international traffic of ships or aircraft shall include in particular :
(a) revenue and gross receipts from the operation of ships or aircraft for the transport of persons, livestock, goods, mail or merchandise in international traffic including :
(i) income derived from the lease by the enterprise of ships or aircraft on a charter basis fully equipped, manned and supplied, used in international traffic ;
(ii) income derived by the enterprise from the sale of tickets and other similar documents for and the provision of services connected with such transport for the enterprise itself or for any other enterprise ;
(iii) interest on funds directly connected with the operation of ships or aircraft in international traffic ;
(b) profits derived from the lease by the enterprise on a bare boat charter basis of ships or aircraft used in international traffic, when such lease is an occasional source of income for such enterprise ;
(c) profits derived from the lease of containers by the enterprise, when such lease is supplementary or incidental to its operations in international traffic.
Number Hok14
HONG KONG (Treaty of 10.12.2003)
Article 14 Income from employment
1. Subject to the provisions of Articles 15, 17 and 18, salaries, wages and other similar remuneration derived by a resident in a Contracting Party in respect of an employment shall be taxable only in that Party unless the employment is exercised in the other Contracting Party. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Party. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident in a Contracting Party in respect of an employment exercised in the other Contracting Party shall be taxable only in the first-mentioned Party if :
(a) the recipient is present in the other Party for a period or periods not exceeding in the aggregate 183 days in any 12-month period commencing or ending in the taxable period concerned, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident in the other Party, and
(c) the remuneration is not borne by a permanent establishment which the employer has in the other Party, and
(d) the remuneration is taxable in the first-mentioned Party according to the laws in force in that Party.
3. Notwithstanding the preceding paragraphs of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting Party may be taxed in that Party.
Number Hok17
HONG KONG (Treaty of 10.12.2003)
Article 17 Pensions and annuities
1. Subject to the provisions of paragraph 2 of Article 18, pensions and other similar remuneration paid to a resident in a Contracting Party in consideration of past employment, and annuities, may be taxed in the Contracting Party in which they arise. This provision shall also apply to pensions and other similar remuneration paid by a Contracting Party under social security laws in force in that Party or paid under a public scheme in force in that Party in order to supplement the benefits of such social security laws.
2. The term "annuity" means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth.
3. Any alimony or other maintenance payment paid by a resident in a Contracting Party to a resident in the other Contracting Party shall be taxable only in the first-mentioned Party. To the extent such payments are not allowed as a relief to the payer in the first-mentioned Party, they shall be deemed to be taxed in that Party for the purposes of Article 22.
4. Pensions shall be deemed to arise in a Contracting Party if paid by or out of a pension fund or other similar institution providing pension schemes in which individuals may participate in order to secure retirement benefits, where such pension fund or institution is recognised for tax purposes or regulated in accordance with the laws of that Party.
Number Hok22
HONG KONG (Treaty of 10.12.2003)
CHAPTER V - METHODS FOR ELIMINATION OF DOUBLE TAXATION
Article 22 Methods for elimination of double taxation
1. In the case of the Hong Kong Special Administrative Region, double taxation shall be avoided as follows :
(a) Subject to the provisions of the laws in force in the Hong Kong Special Administrative Region from time to time which relate to the allowance of a credit against Hong Kong Special Administrative Region tax of tax paid in a jurisdiction outside the Hong Kong Special Administrative Region (which shall not affect the general principle of this Article), Belgian tax paid under the law of Belgium and in accordance with this Agreement, whether directly or by deduction, in respect of income, profits or gains derived by a person who is a resident in the Hong Kong Special Administrative Region from sources in Belgium, shall be allowed as a credit against Hong Kong Special Administrative Region tax payable in respect of the same income, profits or gains, provided that the credit so allowed does not exceed the amount of Hong Kong Special Administrative Region tax computed in respect of the same income, profits or gains in accordance with the tax laws of the Hong Kong Special Administrative Region.
(b) Income, profits or gains derived by a resident in the Hong Kong Special Administrative Region which, under any provision of the Agreement, may be taxed in Belgium shall, for the purposes of sub-paragraph (a), be deemed to be income from sources in Belgium.
2. In the case of Belgium, double taxation shall be avoided as follows :
(a)
Where a resident in Belgium derives elements of income, not being dividends, interest or royalties, which may be taxed in the Hong Kong Special Administrative Region in accordance with the provisions of this Agreement, and which are taxed there, Belgium shall exempt such elements of income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted.
(b) Dividends derived by a company which is a resident in Belgium from a company which is a resident in the Hong Kong Special Administrative Region shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law.
Where a resident in Belgium derives from a company which is a resident in the Hong Kong Special Administrative Region dividends which are included in his aggregate income for Belgian tax purposes and which are not exempted from the corporate income tax according to this sub-paragraph, Belgium shall deduct from the Belgian tax relating to these dividends, Hong Kong Special Administrative Region tax levied on these dividends in accordance with Article 10. This deduction shall not exceed that part of the Belgian tax which is proportionally relating to these dividends.
(c) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident in Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, Hong Kong Special Administrative Region tax levied on that income shall be allowed as a credit against Belgian tax proportionally relating to such income.
(d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident in Belgium through a permanent establishment situated in the Hong Kong Special Administrative Region, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in the Hong Kong Special Administrative Region by reason of compensation for the said losses.