Agreement between the Government of the Kingdom of the Netherlands and the Government of the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income:Article 25 Non-discrimination

Agreement between the Government of the Kingdom of the Netherlands and the Government of the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income

Article 25 Non-discrimination

Geldend

Deze functie is alleen te gebruiken als je bent ingelogd.Deze functie is alleen te gebruiken als je bent ingelogd.Deze functie is alleen te gebruiken als je bent ingelogd.Deze functie is alleen te gebruiken als je bent ingelogd.Deze functie is alleen te gebruiken als je bent ingelogd.

1.

Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States.

2.

The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relief and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

3.

Except where the provisions of paragraph 1 of Article 9, paragraph 4 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.

4.

Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirements connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

5.

The non taxation of Qatari and other members of the Gulf Cooperation Council (GCC) nationals under Qatari tax law shall not be regarded as a discrimination under the provision of this Article.

6.

Contributions made by or on behalf of an individual who renders services in a Contracting State to a pension scheme recognised for tax purposes in the other Contracting State,

(i)

in which the individual participated immediately before beginning to provide services in the first-mentioned State,

(ii)

in which the individual participated at a time when that individual was providing services in, or was a resident of, the other State, and

(iii)

that is accepted by the competent authority of the first-mentioned State as generally corresponding to a pension scheme recognised as such for tax purposes by that State,

shall, for the purposes of determining the individual's tax payable in the first-mentioned State and the profits of an enterprise which may be taxed in the first-mentioned State, be treated in that State in the same way and subject to the same conditions and limitations as contributions made to a pension scheme that is recognised for tax purposes in that State.

For the purposes of this paragraph:

a)

the term ‘a pension scheme’ means an arrangement in which the individual participates in order to secure retirement benefits payable in respect of the services referred to in this paragraph; and

b)

a pension scheme is recognised for tax purposes in a State if the contributions to the scheme would qualify for tax relief in that State.

7.

The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description.

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