Einde inhoudsopgave
Convention between the Kingdom of the Netherlands and the Federative Republic of Brazil for the avoidance of double taxation and the prevention of fiscal evasion with respect of taxes on income
Article 15 Dependent personal services
Geldend
Geldend vanaf 20-11-1991
- Bronpublicatie:
08-03-1990, Trb. 1990, 67 (uitgifte: 16-05-1990, kamerstukken/regelingnummer: -)
- Inwerkingtreding
20-11-1991
- Bronpublicatie inwerkingtreding:
17-12-1991, Trb. 1991, 176 (uitgifte: 01-01-1991, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Voorkoming van dubbele belasting
Internationaal belastingrecht / Belastingverdragen
1.
Subject to the provisions of Articles 16, 18, 19 and 20, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2.
Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
- a)
the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and
- b)
the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and
- c)
the remuneration is not borne by a permanent establishment which the employer has in the other State.
3.
Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.