Einde inhoudsopgave
Agreement between the Kingdom of the Netherlands the Kingdom of Bahrain for the reciprocal exemption with respect to taxes on income and profits derived from international air transport
Article 3 Reciprocal exemption
Geldend
Geldend vanaf 06-07-2011
- Bronpublicatie:
05-02-2007, Trb. 2007, 39 (uitgifte: 09-03-2007, kamerstukken/regelingnummer: -)
- Inwerkingtreding
06-07-2011
- Bronpublicatie inwerkingtreding:
18-08-2011, Trb. 2011, 134 (uitgifte: 18-08-2011, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Vervoersrecht / Luchtvervoer
1.
Income and profits derived from the operation of aircraft in international traffic by an air transport enterprise of a Contracting State shall be exempted from tax in the other Contracting State, irrespective of the manner in which it is levied.
2.
Income and profits derived from the alienation of aircraft operated in international traffic by an air transport enterprise of a Contracting State and movable property pertaining to the operation of such aircraft shall be exempted from tax in the other Contracting State, irrespective of the manner in which it is levied.
3.
For the purposes of this Article, income and profits derived by an air transport enterprise of a Contracting State from the operation of aircraft in international traffic mean income and profits from the transportation by air of persons, baggage, animals, goods or mail, by an air transport enterprise of a Contracting State, including the sale of tickets or similar documents for such transportation. Such income and profits include income and profits derived by that air transport enterprise from activities directly connected with and incidental to the operation of aircraft, in particular:
- a)
profits from the rental, lease or sub-lease of aircraft;
- b)
interest derived from bank deposits directly connected with the operation of aircraft in international traffic;
- c)
income and profits derived from training schemes, management and other services rendered by that air transport enterprise to an air transport enterprise of the other Contracting State.
4.
The provisions of paragraphs 1 and 2 shall also apply to income and profits from the participation in a pool, a joint business or an international operating agency.
5.
Remuneration derived by an employee of an air transport enterprise of a Contracting State in respect of an employment exercised aboard an aircraft operated in international traffic shall be taxable only in that State.
6.
An individual who acquires in one of the Contracting States technical, professional or business experience with respect to the operation of aircraft as an employee of an air transport enterprise of the other Contracting State which operates air services in international traffic shall be exempt from tax in the first-mentioned State with respect to his remuneration received from the aforementioned air transport enterprise for such a purpose for a period of three years.