Convention between the Government of the Kingdom of the Netherlands and the Government of the State of Qatar for the avoidance of double taxation on income and profits derived from international air transport
Article 2 Definitions
Geldend
Geldend vanaf 25-11-2018
- Bronpublicatie:
06-01-2008, Trb. 2008, 59 (uitgifte: 03-04-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
25-11-2018
- Bronpublicatie inwerkingtreding:
15-11-2018, Trb. 2018, 198 (uitgifte: 15-11-2018, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Vervoersrecht / Luchtvervoer
1.
The following terms used in this Convention shall have the meaning as shown hereunder, unless the context otherwise requires:
- a)
the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the State of Qatar and the Kingdom of the Netherlands, as the context requires; the term ‘Contracting States’ means the State of Qatar and the Kingdom of the Netherlands;
- b)
without prejudice to Article 6 of this Convention, the term ‘the Kingdom of the Netherlands’ means the part of the Kingdom of the Netherlands that is situated in Europe;
- c)
the term ‘tax’ means Qatar tax or Netherlands tax as the context requires;
- d)
the term ‘enterprise of a Contracting State’ and ‘enterprise of the other Contracting State’ mean respectively an enterprise involved in international air traffic and whose place of effective management is located in a Contracting State and an enterprise involved in international air traffic and whose place of effective management is located in the other Contracting State. These terms shall be deemed to include those enterprises which are designated to operate air services between the Contracting States;
- e)
the term ‘international air traffic’ means any transport by an aircraft, owned, leased or chartered, operated by an enterprise of a Contracting State, except when the aircraft is operated solely between places in the other Contracting State;
- f)
the term ‘operation of aircraft’ means the transportation by air of persons, baggage, animals, goods or mail, by an enterprise of a Contracting State, including the sale of tickets or similar documents for such transportation, as well as any other activity directly connected with and incidental to the operation of aircraft, in particular:
- i)
the rental or lease of aircraft;
- ii)
the providing of training schemes, management and other services by that enterprise to an enterprise of the other Contracting State;
- g)
the term ‘competent authority’ means:
- i)
in the case of Qatar, the Minister of Finance, or his authorised representative;
- ii)
the case of the Netherlands, the Minister of Finance or his authorised representative.
2.
As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.