BWBV0003112
Geldig vanaf 05-11-2009
Artikel 4
Verdrag tussen het Koninkrijk der Nederlanden en de Staten van Guernsey inzake de toegang tot onderlinge overlegprocedures in verband met winstcorrecties tussen verbonden ondernemingen en de toepassing van de Nederlandse deelnemingsvrijstelling
Where:
a. an enterprise of a Party participates directly or indirectly in the management, control or capital of an enterprise of the other Party, or
b. the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Party and an enterprise of the other Party,
and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
a. an enterprise of a Party participates directly or indirectly in the management, control or capital of an enterprise of the other Party, or
b. the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Party and an enterprise of the other Party,
and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
- Citeren als
- Art. 4
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0003112
- Officiële bron
- wetten.overheid.nl