Agreement between the Government of the Kingdom of Saudi Arabia and the Government of the Kingdom of the Netherlands for reciprocal exemption of taxes levied on income and profits of air transport enterprises from the exercise of air transport in international traffic and their employees
Article 2 Definitions
Geldend
Geldend vanaf 01-01-1992
- Bronpublicatie:
16-01-1991, Trb. 1991, 54 (uitgifte: 26-03-1991, kamerstukken/regelingnummer: -)
- Inwerkingtreding
01-01-1992
- Bronpublicatie inwerkingtreding:
23-12-1991, Trb. 1991, 180 (uitgifte: 01-01-1991, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Vervoersrecht / Luchtvervoer
In this Agreement, unless the context otherwise requires:
- a.
the terms ‘a Contracting State’ and ‘the other Contracting State’ means the Kingdom of the Netherlands or the Kingdom of Saudi Arabia, as the context requires; the term ‘Contracting States’ means the Kingdom of the Netherlands and the Kingdom of Saudi Arabia;
- b.
as regards the Kingdom of the Netherlands, the present Agreement shall apply to the part of the Kingdom which is situated in Europe only;
- c.
the term ‘tax’ means ‘Netherlands tax’ or ‘Saudi tax’ as the context requires;
- d.
the terms ‘air transport enterprise of a Contracting State’ and ‘air transport enterprise of the other Contracting State’ mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State, which is designated by Air Transport Agreement between the Kingdom of the Netherlands and the Kingdom of Saudi Arabia;
- e.
the term ‘exercise of air transport’ means the operational activity of transportation by air of persons, animals, goods and mail conducted by an air transport enterprise of a Contracting State including sale of tickets and similar documents used for the purpose of transportation;
- f.
the terms ‘international traffic’ mean any transport by aircraft, owned, leased or chartered, operated by an air transport enterprise of a Contracting State, except when such transport is made solely between places in the other Contracting State;
- g.
the term ‘competent authority’ means:
- i)
in the case of the Netherlands, the Minister of Finance or his authorised representative; however with respect to social security legislation on ministers responsible for such legislation and their authorised representatives;
- ii)
in the case of the Kingdom of Saudi Arabia, the Ministry of Finance & National Economy;
- h.
the term ‘resident of a Contracting State’ means any person, who under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature;
- i.
the term ‘person’ includes an individual, a company and any other body of persons.
2.
As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies.