BWBV0006497
Artikel VIII
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
The determination of the main purpose referred to in paragraph 10 of Article 10 shall be based on all facts and circumstances including:
a) the nature and volume of the activities of the company in its country of residence in relation to the nature and volume of the dividends;
b) both the historical and the current ownership of the company; and
c) the business reasons for the company residing in its country of residence including the extent to which the company that beneficially owns the dividends would be entitled to treaty benefits comparable to those afforded by this Agreement if it had been a resident of the country of residence of the majority of its shareholders.
a) the nature and volume of the activities of the company in its country of residence in relation to the nature and volume of the dividends;
b) both the historical and the current ownership of the company; and
c) the business reasons for the company residing in its country of residence including the extent to which the company that beneficially owns the dividends would be entitled to treaty benefits comparable to those afforded by this Agreement if it had been a resident of the country of residence of the majority of its shareholders.
- Citeren als
- Art. VIII
- Status
- Geldend recht
- Identificatie
- BWBV0006497
- Officiële bron
- wetten.overheid.nl