BWBV0007096
Geldig vanaf 28-02-2026
Artikel 21
Verdrag tussen het Koninkrijk der Nederlanden, ten behoeve van Curaçao, en de Republiek Cyprus tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen en het voorkomen van het ontduiken en ontwijken van belasting
1. In the case of Cyprus, double taxation shall be avoided as follows:
Subject to the provisions of Cyprus tax law regarding credit for foreign tax, there shall be allowed as a credit against Cyprus tax payable in respect of any item of income derived from Curaçao the tax paid under the laws of Curaçao and in accordance with this Convention. The credit shall not, however, exceed that part of the Cyprus tax, as computed before the credit is given, which is appropriate to such items of income or gain.
2. In the case of Curaçao double taxation shall be avoided as follows:
a) Curaçao may include in the basis upon which taxes are imposed on its residents, the items of income which according to the provisions of this Convention may be taxed or shall be taxable only in Cyprus. In such cases, however, Curaçao shall allow a reduction or deduction from the Curaçaos tax according to the provisions of paragraphs b, c and d;
b) Where a resident of Curaçao derives items of income which according to paragraph 1 of Article 6, paragraph 1 of Article 7, paragraphs 1, 2 and 4 of Article 13, paragraphs 1 and 3 of Article 14, Article 16, paragraph 1 (subparagraph a) of Article 17, Article 18 and paragraph 2 of Article 20 of this Convention may be taxed in the other Contracting State and are included in the basis referred to in paragraph 2 (a), Curaçao shall exempt such items of income by allowing a deduction of the Curaçao tax. This deduction is calculated based on the exemption with progression method taking into account the provisions of laws of Curaçao for the avoidance of double taxation where applicable;
c) The provisions of paragraph 2 (b) shall not apply to items of income derived by a resident of Curaçao where the other Contracting State applies the provisions of this Convention to exempt such items of income from tax. In such case, the provisions of paragraph 2 (d) shall apply accordingly;
d) Further, Curaçao shall allow a deduction from Curaçao tax so computed for the items of income which according to paragraph 1 of Article 15, and Article 16, of this Convention may be taxed in the other Contracting State to the extent that these items are included in the basis referred to in paragraph 2 (a). This deduction shall be computed in conformity with the provisions of laws of Curaçao for the elimination of double taxation.
Subject to the provisions of Cyprus tax law regarding credit for foreign tax, there shall be allowed as a credit against Cyprus tax payable in respect of any item of income derived from Curaçao the tax paid under the laws of Curaçao and in accordance with this Convention. The credit shall not, however, exceed that part of the Cyprus tax, as computed before the credit is given, which is appropriate to such items of income or gain.
2. In the case of Curaçao double taxation shall be avoided as follows:
a) Curaçao may include in the basis upon which taxes are imposed on its residents, the items of income which according to the provisions of this Convention may be taxed or shall be taxable only in Cyprus. In such cases, however, Curaçao shall allow a reduction or deduction from the Curaçaos tax according to the provisions of paragraphs b, c and d;
b) Where a resident of Curaçao derives items of income which according to paragraph 1 of Article 6, paragraph 1 of Article 7, paragraphs 1, 2 and 4 of Article 13, paragraphs 1 and 3 of Article 14, Article 16, paragraph 1 (subparagraph a) of Article 17, Article 18 and paragraph 2 of Article 20 of this Convention may be taxed in the other Contracting State and are included in the basis referred to in paragraph 2 (a), Curaçao shall exempt such items of income by allowing a deduction of the Curaçao tax. This deduction is calculated based on the exemption with progression method taking into account the provisions of laws of Curaçao for the avoidance of double taxation where applicable;
c) The provisions of paragraph 2 (b) shall not apply to items of income derived by a resident of Curaçao where the other Contracting State applies the provisions of this Convention to exempt such items of income from tax. In such case, the provisions of paragraph 2 (d) shall apply accordingly;
d) Further, Curaçao shall allow a deduction from Curaçao tax so computed for the items of income which according to paragraph 1 of Article 15, and Article 16, of this Convention may be taxed in the other Contracting State to the extent that these items are included in the basis referred to in paragraph 2 (a). This deduction shall be computed in conformity with the provisions of laws of Curaçao for the elimination of double taxation.
- Citeren als
- Art. 21
- Geldig vanaf
- Status
- Geldend recht
- Identificatie
- BWBV0007096
- Officiële bron
- wetten.overheid.nl