BWBV0002801
Geldig vanaf 05-02-1999
Artikel 24
Overeenkomst tussen de Regering van het Koninkrijk der Nederlanden en de Regering van Maleisië tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen
1. Nationals of one of the States shall not be subjected in the other State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirement to which nationals of that other State in the same circumstances are or may be subjected.
2. The taxation on a permanent establishment which an enterprise of one of the States has in the other State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.
3. Except where the provisions of Article 10, paragraph 8 of Article 12, paragraph 10 of Article 13, or paragraph 7 of Article 13A, apply, interest, royalties and other disbursements paid by an enterprise of one of the States to a resident of the other State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Provided that in such cases the conditions of the domestic law of the first-mentioned State are fulfilled.
4. Enterprises of one of the States, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected in the same circumstances and under the same conditions.
5. Nothing in this Article shall be construed as obliging:
(a) a State to grant to individuals who are resident of the other State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents;
(b) Malaysia to grant to nationals of the Netherlands not resident in Malaysia those personal allowances, reliefs and reductions for tax purposes which are by law available on the date of signature of this Agreement only to nationals of Malaysia who are not resident in Malaysia.
6. In this Article, the term “taxation” means taxes which are the subject of this Agreement.
2. The taxation on a permanent establishment which an enterprise of one of the States has in the other State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.
3. Except where the provisions of Article 10, paragraph 8 of Article 12, paragraph 10 of Article 13, or paragraph 7 of Article 13A, apply, interest, royalties and other disbursements paid by an enterprise of one of the States to a resident of the other State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Provided that in such cases the conditions of the domestic law of the first-mentioned State are fulfilled.
4. Enterprises of one of the States, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected in the same circumstances and under the same conditions.
5. Nothing in this Article shall be construed as obliging:
(a) a State to grant to individuals who are resident of the other State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents;
(b) Malaysia to grant to nationals of the Netherlands not resident in Malaysia those personal allowances, reliefs and reductions for tax purposes which are by law available on the date of signature of this Agreement only to nationals of Malaysia who are not resident in Malaysia.
6. In this Article, the term “taxation” means taxes which are the subject of this Agreement.
- Citeren als
- Art. 24
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0002801
- Officiële bron
- wetten.overheid.nl