Artikel IX

1. Where tax has been levied at source in excess of the amount of tax chargeable under the provisions of Articles 10, 11 or 12, applications for the refund of the excess amount of tax have to be lodged with the competent authority of the State having levied the tax, within a period of five years after the expiration of the calendar year in which the tax has been levied.
2. As soon as the laws or regulations of the Kingdom of Saudi Arabia give to residents of other countries, except countries that are member of the Gulf Cooperation Counsel and the Arabic League, national treatment with regard to taxation such national treatment will automatically be provided to residents or former residents of the Netherlands.
3. The Kingdom of Saudi Arabia shall with respect to its national laws and regulations treat nationals or residents of the Netherlands for taxation purposes not less favourable than residents or nationals from third countries except countries that are member of the Gulf Cooperation Counsel and the Arabic League.
4. In case the Kingdom of Saudi Arabia introduces any form of dispute resolution mechanism, including binding dispute resolution, with any country in a tax convention the Contracting States shall enter into negotiations to insert an Article concerning dispute resolution.
5. In case the Kingdom of Saudi Arabia introduces an Article concerning the assistance in recovery with any country in a tax convention the Contracting States shall enter into negotiations to insert an Article for the assistance and support in the collection of the taxes to which this Convention applies.
6. Profits which are exempt for a limited period of time not exceeding ten years from tax on income in Saudi Arabia under the provisions of encouragement of its investment laws shall be deemed to be subject to a tax on income for the purpose of the application of the participation exemption by the Netherlands.