BWBV0002453
Geldig vanaf 24-01-1984
Artikel 8
Overeenkomst tussen het Koninkrijk der Nederlanden en de Democratische Socialistische Republiek Sri Lanka 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 aircraft in international traffic shall be taxable only in the State in which the place of effective management of the enterprise is situated.
2. Profits from the operation of ships in international traffic may be taxed in the State in which the place of effective management of the enterprise is situated.
However, if the operation of a ship in the other State is more than casual, such profits may also be taxed in that other State and according to the laws of that State, but only so much of them as is derived from that other State.
For the purposes of this paragraph:
(a) profits derived from the other State mean profits from the carriage of passengers or freight embarked in that other State;
(b) the amount of such profits shall not exceed 6 per cent of the sums receivable in respect of such carriage;
(c) the tax chargeable in the other State on the amount of such profits shall be reduced by 50 per cent.
3. The provisions of paragraphs (1) and (2) of this Article shall likewise apply in respect of profits from the participation in a pool, a joint business or international operating agency of any kind by enterprises engaged in the operation of ships or aircraft in international traffic.
4. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the State in which the home harbour of the ship is situated, or if there is no such home harbour, in the State of which the operator of the ship is a resident.
2. Profits from the operation of ships in international traffic may be taxed in the State in which the place of effective management of the enterprise is situated.
However, if the operation of a ship in the other State is more than casual, such profits may also be taxed in that other State and according to the laws of that State, but only so much of them as is derived from that other State.
For the purposes of this paragraph:
(a) profits derived from the other State mean profits from the carriage of passengers or freight embarked in that other State;
(b) the amount of such profits shall not exceed 6 per cent of the sums receivable in respect of such carriage;
(c) the tax chargeable in the other State on the amount of such profits shall be reduced by 50 per cent.
3. The provisions of paragraphs (1) and (2) of this Article shall likewise apply in respect of profits from the participation in a pool, a joint business or international operating agency of any kind by enterprises engaged in the operation of ships or aircraft in international traffic.
4. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the State in which the home harbour of the ship is situated, or if there is no such home harbour, in the State of which the operator of the ship is a resident.
- Citeren als
- Art. 8
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0002453
- Officiële bron
- wetten.overheid.nl