BWBV0002958
Geldig vanaf 11-12-1997
Artikel 4
Tweede Protocol bij de op 29 mei 1991 te Den Haag ondertekende overeenkomst tussen het Koninkrijk der Nederlanden en de Republiek Venezuela tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen
It is understood that the provisions of Articles I and VII of the Protocol to the Convention do not apply when the beneficial owner of such income is an individual or the Government of the Republic of Venezuela, one of the States of the Republic of Venezuela, a municipality of Venezuela or a company, public or private, which is a resident of Venezuela
– where the Republic of Venezuela, one of the States of Venezuela or a municipality of Venezuela ownst at least fifty percent (50%) of the capital stock of such company, or
– where such company is engaged in an active trade or business in Venezuela, or
– where in the principal class of shares in such company there is substantial and regular trading on the Maracaibo and Caracas Stock Exchanges,
provided that such company receiving the income in Venezuela is the beneficial owner of such income. Further the provisions of Articles I and VII of the Protocol to the Convention shall not apply in cases where the competent authorities of the Contracting States in conformity with Article 26 of the Convention mutually agree that it is established that any other company receiving such income in Venezuela is a resident of Venezuela according to the provisions of Articles 1 and 4 of the Convention and that such company is not established or maintained in Venezuela mainly for the purpose of ensuring the benefits of paragraph 3 of Article 10 of the Convention.
– where the Republic of Venezuela, one of the States of Venezuela or a municipality of Venezuela ownst at least fifty percent (50%) of the capital stock of such company, or
– where such company is engaged in an active trade or business in Venezuela, or
– where in the principal class of shares in such company there is substantial and regular trading on the Maracaibo and Caracas Stock Exchanges,
provided that such company receiving the income in Venezuela is the beneficial owner of such income. Further the provisions of Articles I and VII of the Protocol to the Convention shall not apply in cases where the competent authorities of the Contracting States in conformity with Article 26 of the Convention mutually agree that it is established that any other company receiving such income in Venezuela is a resident of Venezuela according to the provisions of Articles 1 and 4 of the Convention and that such company is not established or maintained in Venezuela mainly for the purpose of ensuring the benefits of paragraph 3 of Article 10 of the Convention.
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- Art. 4
- Geldig vanaf
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- BWBV0002958
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