BWBV0002851
Geldig vanaf 20-09-1991
Artikel 16
Overeenkomst tussen het Koninkrijk der Nederlanden en de Republiek der Filippijnen tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen
1. Directors' fees and other remuneration derived by a resident of the Netherlands in his capacity as a member of the board of directors of a company which is a resident of the Philippines may be taxed in the Philippines.
2. Directors' fees and other remuneration derived by a resident of the Philippines in his capacity as a "bestuurder" or a "commissaris" of a company which is a resident of the Netherlands may be taxed in the Netherlands.
3. Where the remuneration mentioned above is derived by persons, who exercise activities in real and regular functions in a permanent establishment situated in the other State than the State of which the company is a resident, and is borne as such by that permanent establishment, then, notwithstanding the provisions of paragraphs 1 and 2, such remuneration may be taxed in the State in which the permanent establishment is situated.
2. Directors' fees and other remuneration derived by a resident of the Philippines in his capacity as a "bestuurder" or a "commissaris" of a company which is a resident of the Netherlands may be taxed in the Netherlands.
3. Where the remuneration mentioned above is derived by persons, who exercise activities in real and regular functions in a permanent establishment situated in the other State than the State of which the company is a resident, and is borne as such by that permanent establishment, then, notwithstanding the provisions of paragraphs 1 and 2, such remuneration may be taxed in the State in which the permanent establishment is situated.
- Citeren als
- Art. 16
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0002851
- Officiële bron
- wetten.overheid.nl