BWBV0001263
Geldig vanaf 02-05-1997
Artikel V
Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Kazachstan 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
Where,
(i) the only significant component of a contract is the performance of technical services, including the performance of studies or surveys of a scientific, geological or technical nature, or the provision of consultancy or supervisory services, and not the transfer or assignment of designs, plans, processes, scientific or commercial experience, or other rights described in paragraph 4 of Article 12, and
(ii) no element of the payment under the contract is proportional to the income or revenues (or other similar factor) of the beneficiary of the services, and
(iii) the value of any component of the contract which is attributable to the transfer of rights described in paragraph 4 of Article 12 does not exceed the lesser of 10 percent of the total value of the contract or 50,000 US dollars, then payments received as consideration for such services shall be deemed to be payments to which Article 7 or Article 14 apply. In other cases, where contracts are of a “mixed” nature, amounts paid under the contract may be allocated to reflect the fact that one part of such payments should be considered as payments for services, and the other part as royalties subject to tax under Article 12.
(i) the only significant component of a contract is the performance of technical services, including the performance of studies or surveys of a scientific, geological or technical nature, or the provision of consultancy or supervisory services, and not the transfer or assignment of designs, plans, processes, scientific or commercial experience, or other rights described in paragraph 4 of Article 12, and
(ii) no element of the payment under the contract is proportional to the income or revenues (or other similar factor) of the beneficiary of the services, and
(iii) the value of any component of the contract which is attributable to the transfer of rights described in paragraph 4 of Article 12 does not exceed the lesser of 10 percent of the total value of the contract or 50,000 US dollars, then payments received as consideration for such services shall be deemed to be payments to which Article 7 or Article 14 apply. In other cases, where contracts are of a “mixed” nature, amounts paid under the contract may be allocated to reflect the fact that one part of such payments should be considered as payments for services, and the other part as royalties subject to tax under Article 12.
- Citeren als
- Art. V
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0001263
- Officiële bron
- wetten.overheid.nl