BWBV0001453
Geldig vanaf 06-04-2001
Artikel 8
Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Kroatië 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. Profits from the operation of ships, boats engaged in inland waterways transport or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
3. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
4. For the purpose of this Article, profits derived by an enterprise of a Contracting State from the operation in international traffic of ships, boats engaged in inland waterways transport and aircraft include:
a) interest on sums generated directly from the operation of ships, boats and aircraft in international traffic provided that such interest is incidental to the operation; and
b) (i) profits derived from the charter or rental of ships, boats and aircraft, on a bareboat basis,
(ii) profits derived from the rental of containers and related equipment, by that enterprise, provided that such charter or rental is incidental to the operation by that enterprise of ships, boats and aircraft in international traffic.
(i) profits derived from the charter or rental of ships, boats and aircraft, on a bareboat basis,
(ii) profits derived from the rental of containers and related equipment,
2. If the place of effective management of a shipping enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
3. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
4. For the purpose of this Article, profits derived by an enterprise of a Contracting State from the operation in international traffic of ships, boats engaged in inland waterways transport and aircraft include:
a) interest on sums generated directly from the operation of ships, boats and aircraft in international traffic provided that such interest is incidental to the operation; and
b) (i) profits derived from the charter or rental of ships, boats and aircraft, on a bareboat basis,
(ii) profits derived from the rental of containers and related equipment, by that enterprise, provided that such charter or rental is incidental to the operation by that enterprise of ships, boats and aircraft in international traffic.
(i) profits derived from the charter or rental of ships, boats and aircraft, on a bareboat basis,
(ii) profits derived from the rental of containers and related equipment,
- Citeren als
- Art. 8
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0001453
- Officiële bron
- wetten.overheid.nl