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Article 25 Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Argentinië tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen en naar het vermogen

ELIMINATION OF DOUBLE TAXATION

1 In the case of Argentina, double taxation shall be avoided as follows:

Where a resident of Argentina derives income which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, Argentina shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the Netherlands. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in the Netherlands.

2 The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income or capital which, according to the provisions of this Convention, may be taxed in Argentina.

3 However, where a resident of the Netherlands derives items of income, or owns items of capital which according to Article 6, Article 7, paragraph 6 of Article 10, paragraph 7 of Article 12, paragraph 5 of Article 13, paragraphs 1 and 3 of Article 14, paragraph 2 (subparagraph a)) of Article 15, paragraph 1 of Article 16, paragraph 3 of Article 19, paragraph 1 (subparagraph a)) and 2 (subparagraph a)) of Article 20, paragraph 2 of Article 23 and paragraphs 1 and 3 of Article 24 of this Convention may be taxed in Argentina and are included in the basis referred to in paragraph 2, the Netherlands shall exempt such items of income or capital by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of Netherlands law for the avoidance of double taxation. For that purpose the said items of income or capital shall be deemed to be included in the total amount of the items of income or capital which are exempt from Netherlands tax under those provisions.

4 Notwithstanding the provisions of paragraph 3, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 5 of Article 7 of this Convention may be taxed in Argentina and where the insurance or reinsurance activities are not carried on through a permanent establishment situated in Argentina, but only to the extent that these items of income are included in the basis referred to in paragraph 2. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income or capital which according to paragraph 2 of Article 10, paragraph 2 of Article 12, paragraph 2 of Article 13, paragraphs 2, 5 and 6 of Article 14, paragraph 2 (subparagraph b)) of Article 15, paragraph 3 of Article 16, Article 17, Article 18, paragraph 2 of Article 19, paragraph 3 of Article 23 and paragraphs 2, 5 and 6 of Article 24 of this Convention may be taxed in Argentina to the extent that these items are included in the basis referred to in paragraph 2. The amount of these deductions shall be equal to the tax paid in Argentina on these items of income or capital, but shall not exceed the amount of the reduction which would be allowed if the items of income or capital so included were the sole items of income or capital which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.

Regeling
Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Argentinië tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen en naar het vermogen
Soort
Verdrag
Geldend vanaf
11-02-1998
BWB-id
BWBV0001304
Versie
1998-02-11_0

In de hele regeling · Officiële tekst op wetten.overheid.nl