BWBV0001303
Geldig vanaf 27-08-1998
Artikel 23
Verdrag tussen de Regering van het Koninkrijk der Nederlanden en de Regering van de Russische Federatie 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
1. The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income or property which, according to the provisions of this Agreement, may be taxed in Russia.
2. However, where a resident of the Netherlands derives items of income which according to article 6, article 7, paragraph 5 of article 10, paragraph 3 of article 11, paragraph 3 of article 12, paragraphs 1 and 2 of article 13, article 14, paragraph 1 of article 15, paragraph 3 and paragraph 4 (sub-paragraph a) of article 18, paragraph 1 (sub-paragraph a) of article 19 and paragraph 2 of article 21 of this Agreement may be taxed in Russia and are included in the basis referred to in paragraph 1, the Netherlands shall exempt such items of income 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 shall be deemed to be included in the total amount of the items of income which are exempt from Netherlands tax under those provisions.
3. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income or property which according to paragraph 2 of article 10, paragraph 5 of article 13, article 16, article 17, paragraph 2 of article 18 and article 22 of this Agreement may be taxed in Russia to the extent that these items are included in the basis referred to in paragraph 1. The amount of this deduction shall be equal to the tax paid in Russia on these items of income or property, but shall not exceed the amount of the reduction which would be allowed if the items of income or property so included were the sole items of income or property which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
4. In the case of Russia double taxation is eliminated as follows: where a resident of Russia derives income or owns property which, in accordance with the provisions of this Agreement, may be taxed in the Netherlands, the amount of tax on that income or property payable in the Netherlands, may be credited against the tax imposed on this resident of Russia. The amount of credit, however, shall not exceed the amount of the tax on that income or property computed in accordance with the taxation laws and regulations of Russia.
For the purposes of this paragraph, the taxes referred to in paragraphs 3a) and 4 of article 2, other than the property tax, shall be considered taxes on income.
2. However, where a resident of the Netherlands derives items of income which according to article 6, article 7, paragraph 5 of article 10, paragraph 3 of article 11, paragraph 3 of article 12, paragraphs 1 and 2 of article 13, article 14, paragraph 1 of article 15, paragraph 3 and paragraph 4 (sub-paragraph a) of article 18, paragraph 1 (sub-paragraph a) of article 19 and paragraph 2 of article 21 of this Agreement may be taxed in Russia and are included in the basis referred to in paragraph 1, the Netherlands shall exempt such items of income 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 shall be deemed to be included in the total amount of the items of income which are exempt from Netherlands tax under those provisions.
3. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income or property which according to paragraph 2 of article 10, paragraph 5 of article 13, article 16, article 17, paragraph 2 of article 18 and article 22 of this Agreement may be taxed in Russia to the extent that these items are included in the basis referred to in paragraph 1. The amount of this deduction shall be equal to the tax paid in Russia on these items of income or property, but shall not exceed the amount of the reduction which would be allowed if the items of income or property so included were the sole items of income or property which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
4. In the case of Russia double taxation is eliminated as follows: where a resident of Russia derives income or owns property which, in accordance with the provisions of this Agreement, may be taxed in the Netherlands, the amount of tax on that income or property payable in the Netherlands, may be credited against the tax imposed on this resident of Russia. The amount of credit, however, shall not exceed the amount of the tax on that income or property computed in accordance with the taxation laws and regulations of Russia.
For the purposes of this paragraph, the taxes referred to in paragraphs 3a) and 4 of article 2, other than the property tax, shall be considered taxes on income.
- Citeren als
- Art. 23
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0001303
- Officiële bron
- wetten.overheid.nl