BWBV0002531
Geldig vanaf 21-04-1991
Artikel 8
Overeenkomst tussen het Koninkrijk der Nederlanden en de Republiek Zimbabwe tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen en naar vermogenswinsten
1. Profits from international traffic shall be taxable only in the 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, 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.
3. For the purposes of this Article, profits derived from the operation in international traffic of ships and aircraft include profits derived from the rental on a full or bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to the profits described in paragraph 1 of this Article.
4. The provisions of paragraph 1 of this Article shall apply also to profits from the participation in a pool, a joint business or an international operating agency.
2. 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.
3. For the purposes of this Article, profits derived from the operation in international traffic of ships and aircraft include profits derived from the rental on a full or bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to the profits described in paragraph 1 of this Article.
4. The provisions of paragraph 1 of this Article shall apply also to profits from the participation in a pool, a joint business or an international operating agency.
- Citeren als
- Art. 8
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0002531
- Officiële bron
- wetten.overheid.nl