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Article 11 Verdrag tussen de Regering van het Koninkrijk der Nederlanden en de Regering van de Republiek Congo inzake luchtdiensten

FINANCIAL PROVISIONS

1 Profits from the operation of aircraft in international traffic shall be taxable only in the State in which the place of effective management of the Designated Airline is situated.

2 Gains from the alienation of aircraft operated in international traffic or movable property pertaining to the operation of such aircraft, shall be taxable only in the State in which the place of effective management of the Designated Airline is situated.

3 The provisions of this Article shall also apply to income and profits from the participation in a pool, a joint business, a cooperative marketing arrangement or an international operating agency.

4 The provisions of this Article shall also apply to taxes levied on the basis of the gross receipts in respect of the carriage of passengers and cargo in international traffic.

5 The place of effective management of the enterprise of Koninklijke Luchtvaartmaatschappij N.V. (KLM N.V.) shall be deemed to be situated in the Netherlands, as long as the Netherlands has an exclusive taxing right with respect to the enterprise of KLM N.V. under the tax agreement concluded between the Netherlands and France.

6 The provision of paragraph 5 shall also apply in any situation where the air transport activities of the existing KLM N.V. would be continued fully or substantially by another person. This person shall be considered to be a resident of the Netherlands for the purposes of this Agreement.

7 Remuneration derived by a resident of a Contracting Party in respect of an employment exercised aboard an aircraft operated in international traffic, shall be taxable only in that Contracting Party.

8 If an agreement between the Contracting Parties on avoidance of double taxation and the prevention of fiscal evasion on income (hereinafter: “tax agreement”) in which air transport is addressed envisages procedures different from those referred to in the previous paragraphs of this Article, the provisions of the tax agreement shall be applicable.

Regeling
Verdrag tussen de Regering van het Koninkrijk der Nederlanden en de Regering van de Republiek Congo inzake luchtdiensten
Soort
Verdrag
Geldend vanaf
01-02-2020
BWB-id
BWBV0006360
Versie
2020-02-01_0

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