BWBV0001380
Geldig vanaf 21-04-1999
Artikel 24
Verdrag tussen de Regering van het Koninkrijk der Nederlanden en de Macedonische Regering 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 Contracting State, 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 the Macedonian Contracting State.
2. However, where a Netherlands resident derives items of income or owns items of capital which according to Article 6, Article 7, paragraph 7 of Article 10, paragraph 4 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, Article 14, paragraph 1 of Article 15, paragraph 1 (subparagraph a), paragraph 2 (subparagraph a) and paragraph 4 of Article 19, paragraph 2 of Article 22 and paragraphs 1 and 2 of Article 23 of this Convention may be taxed in the Macedonian Contracting State and are included in the basis referred to in paragraph 1, the Netherlands Contracting State 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.
3. Further, the Netherlands Contracting State shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 of Article 10, paragraph 5 of Article 13, Article 16, Article 17 and paragraph 2 of Article 18 of this Convention may be taxed in the Macedonian Contracting State 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 the Macedonian Contracting State on these items of income, but shall not exceed the amount of the reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
4. Notwithstanding the provisions of paragraph 2, the Netherlands Contracting State shall allow a deduction from the Netherlands tax for the tax paid in the Macedonian Contracting State on items of income which according to Article 7, paragraph 7 of Article 10, paragraph 4 of Article 11, paragraph 4 of Article 12, Article 14 and paragraph 2 of Article 22 of this Convention may be taxed in the Macedonian Contracting State to the extent that these items are included in the basis referred to in paragraph 1, if and insofar as the Netherlands Contracting State under the provisions of Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 3 of this Article shall apply accordingly.
5. Where a Macedonian resident derives income or owns capital which in accordance with the provisions of this Convention may be taxed in the Netherlands Contracting State, the Macedonian Contracting State shall allow:
a) as deduction of the income tax of that resident an amount equal to the amount of the income tax paid in the Netherlands Contracting State,
b) as deduction of the capital tax of that resident an amount equal to the amount of the capital tax paid in the Netherlands Contracting State, such deductions shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable to the income or the capital which may be taxed in the Netherlands Contracting State.
c) Where in accordance with any provision of the Convention income derived or capital owned by a Macedonian resident is exempt from tax in the Macedonian Contracting State, the Macedonian Contracting State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
2. However, where a Netherlands resident derives items of income or owns items of capital which according to Article 6, Article 7, paragraph 7 of Article 10, paragraph 4 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, Article 14, paragraph 1 of Article 15, paragraph 1 (subparagraph a), paragraph 2 (subparagraph a) and paragraph 4 of Article 19, paragraph 2 of Article 22 and paragraphs 1 and 2 of Article 23 of this Convention may be taxed in the Macedonian Contracting State and are included in the basis referred to in paragraph 1, the Netherlands Contracting State 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.
3. Further, the Netherlands Contracting State shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 of Article 10, paragraph 5 of Article 13, Article 16, Article 17 and paragraph 2 of Article 18 of this Convention may be taxed in the Macedonian Contracting State 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 the Macedonian Contracting State on these items of income, but shall not exceed the amount of the reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
4. Notwithstanding the provisions of paragraph 2, the Netherlands Contracting State shall allow a deduction from the Netherlands tax for the tax paid in the Macedonian Contracting State on items of income which according to Article 7, paragraph 7 of Article 10, paragraph 4 of Article 11, paragraph 4 of Article 12, Article 14 and paragraph 2 of Article 22 of this Convention may be taxed in the Macedonian Contracting State to the extent that these items are included in the basis referred to in paragraph 1, if and insofar as the Netherlands Contracting State under the provisions of Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 3 of this Article shall apply accordingly.
5. Where a Macedonian resident derives income or owns capital which in accordance with the provisions of this Convention may be taxed in the Netherlands Contracting State, the Macedonian Contracting State shall allow:
a) as deduction of the income tax of that resident an amount equal to the amount of the income tax paid in the Netherlands Contracting State,
b) as deduction of the capital tax of that resident an amount equal to the amount of the capital tax paid in the Netherlands Contracting State, such deductions shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable to the income or the capital which may be taxed in the Netherlands Contracting State.
c) Where in accordance with any provision of the Convention income derived or capital owned by a Macedonian resident is exempt from tax in the Macedonian Contracting State, the Macedonian Contracting State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
- Citeren als
- Art. 24
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0001380
- Officiële bron
- wetten.overheid.nl