Article XVII Protocol tot wijziging van de Overeenkomst tussen het Koninkrijk der Nederlanden en Canada tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen, met Protocol
1 This Protocol shall enter into force on the thirtieth day after the latter of the dates on which the respective Governments have notified each other in writing that the formalities constitutionally required in their respective States have been complied with, and its provisions shall have effect:
a) in the case of the Netherlands,
(i) for tax withheld at the source on pensions and other payments bed in Article 18 of the Convention as amended by Article VII of this Protocol, to amounts paid on or after the first day of January in the calendar year following that in which the Protocol has entered into force;
(ii) for all other taxes, for taxable years and periods beginning on or after the first day of January 1993;
b) in the case of Canada,
(i) for tax withheld at the source with respect to amounts paid on or after the first day of January 1993, except that the reference in subparagraph a) of paragraph 2 of Article 10 of the Convention, as amended by this Protocol, to “5 per cent” shall be read, in its cation to amounts paid after that first day, after:
(A) 1992 and before 1994, as “9 per cent”;
(B) 1993 and before 1995, as “8 per cent”;
(C) 1994 and before 1996, as “7 per cent”;
(D) 1995 and before 1997, as “6 per cent”;
(ii) for other taxes, with repect to taxable years beginning on or after the first day of January 1993, except that the reference in paragraph 7 of Article 10 of the Convention to subparagraph a) of paragraph 2 shall be read, in its application to taxable years beginning on or after that first day and ending after:
(A) 1992 and before 1994, as “9 per cent”;
(B) 1993 and before 1995, as “8 per cent”;
(C) 1994 and before 1996, as “7 per cent”;
(D) 1995 and before 1997, as “6 per cent”.
2 Where any greater relief from tax would have been afforded by any provision of the Convention than under the Convention as amended by this Protocol, any such provision shall continue to have effect up to and including the taxable year in which this Protocol enters into force.
3 It is understood that the term “paid” shall have the meaning which it has under the law of the State in which the payment arises.
- Regeling
- Protocol tot wijziging van de Overeenkomst tussen het Koninkrijk der Nederlanden en Canada tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen, met Protocol
- Soort
- Verdrag
- Geldend vanaf
- 30-07-1994
- BWB-id
- BWBV0002965
- Versie
- 1994-07-30_0