BWBV0006497
Artikel I
Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Malawi tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen
1. It is understood that the provisions of this Agreement which are identical or in substance similar to the provisions of the OECD Model Tax Convention On Income and On Capital shall be interpreted in accordance with the OECD Commentary thereon at the moment of application of this Agreement.
2. Where entities are considered to be transparent by one of the Contracting States and are considered to be non-transparent by the other Contracting State, and this leads to double taxation or taxation not in accordance with the provisions of this Agreement, the competent authorities of the Contracting States shall find solutions pursuant to Article 24 in order to avoid double taxation or taxation not in accordance with the Agreement and, at the same time, to prevent that, merely as a result of the application of the Agreement income is (partly) not subject to tax.
2. Where entities are considered to be transparent by one of the Contracting States and are considered to be non-transparent by the other Contracting State, and this leads to double taxation or taxation not in accordance with the provisions of this Agreement, the competent authorities of the Contracting States shall find solutions pursuant to Article 24 in order to avoid double taxation or taxation not in accordance with the Agreement and, at the same time, to prevent that, merely as a result of the application of the Agreement income is (partly) not subject to tax.
- Citeren als
- Art. I
- Status
- Geldend recht
- Identificatie
- BWBV0006497
- Officiële bron
- wetten.overheid.nl