BWBV0002712
Geldig vanaf 31-12-1990
Artikel 8
Overeenkomst tussen het Koninkrijk der Nederlanden en het Koninkrijk Noorwegen tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen
1. Profits derived by a resident of one of the States from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. However, such profits may also be taxed in the other State, if the place of effective management of the enterprise is situated in that other State.
3. For the purposes of paragraphs 1 and 2, profits derived from the operation in international traffic of ships or aircraft include profits incidental thereto, such as profits derived by a domestic or international carrier from the lease of ships or aircraft, attributable to temporary capacity on a bareboat basis.
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.
5. The provisions of paragraphs 1 to 4 shall likewise apply to profits derived from the operation of vessels engaged in fishing activities on the high seas.
6. The provisions of paragraphs 1, 2, 3 and 5 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
2. However, such profits may also be taxed in the other State, if the place of effective management of the enterprise is situated in that other State.
3. For the purposes of paragraphs 1 and 2, profits derived from the operation in international traffic of ships or aircraft include profits incidental thereto, such as profits derived by a domestic or international carrier from the lease of ships or aircraft, attributable to temporary capacity on a bareboat basis.
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.
5. The provisions of paragraphs 1 to 4 shall likewise apply to profits derived from the operation of vessels engaged in fishing activities on the high seas.
6. The provisions of paragraphs 1, 2, 3 and 5 shall also apply 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
- BWBV0002712
- Officiële bron
- wetten.overheid.nl