BWBV0001423
Geldig vanaf 11-08-2000
Artikel II
Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Portugal 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. An individual living aboard a ship without any real domicile in either of the Contracting States shall be deemed to be a resident of the Contracting State in which the ship has its home harbour.
2. A pension fund recognised as such in a Contracting State and of which the income is generally exempt from tax in that State, shall be regarded as a resident of that State. As a recognised pension fund of a Contracting State shall be considered any pension fund recognised and controlled according to statutory provisions of that State.
3. Residents of a Contracting State which benefit from a favourable tax treatment shall not be entitled to the benefits of Chapter III of this Convention in so far as domestic transactions comparable to the transactions to which this favourable tax treatment is applicable are excluded from this favourable tax treatment (ring fenced).
4. Residents of a Contracting State which benefit from tax measures which are harmful within the meaning of the EC-Code of conduct for business taxation, as agreed by the Ecofin-meeting of December 1, 1997, shall not be entitled to the benefits of Chapter III of this Convention.
5. However, tax measures referred to in paragraphs 3 and 4 above shall not be considered harmful if they are accepted and to the extent they are authorised by the European Community as an appropriate support for the economic development of a particular area and do not undermine the integrity and coherence of the Community legal order, including the internal market and common policies.
2. A pension fund recognised as such in a Contracting State and of which the income is generally exempt from tax in that State, shall be regarded as a resident of that State. As a recognised pension fund of a Contracting State shall be considered any pension fund recognised and controlled according to statutory provisions of that State.
3. Residents of a Contracting State which benefit from a favourable tax treatment shall not be entitled to the benefits of Chapter III of this Convention in so far as domestic transactions comparable to the transactions to which this favourable tax treatment is applicable are excluded from this favourable tax treatment (ring fenced).
4. Residents of a Contracting State which benefit from tax measures which are harmful within the meaning of the EC-Code of conduct for business taxation, as agreed by the Ecofin-meeting of December 1, 1997, shall not be entitled to the benefits of Chapter III of this Convention.
5. However, tax measures referred to in paragraphs 3 and 4 above shall not be considered harmful if they are accepted and to the extent they are authorised by the European Community as an appropriate support for the economic development of a particular area and do not undermine the integrity and coherence of the Community legal order, including the internal market and common policies.
- Citeren als
- Art. II
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0001423
- Officiële bron
- wetten.overheid.nl