Einde inhoudsopgave
Convention between the Kingdom of the Netherlands and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital
Article 14 Independent personal services
Geldend
Geldend vanaf 21-01-1989
- Redactionele toelichting
De inwerkingtreding is gecorrigeerd via een rectificatie (Trb. 1989, 168).
- Bronpublicatie:
30-07-1988, Trb. 1988, 122 (uitgifte: 09-09-1988, kamerstukken/regelingnummer: -)
- Inwerkingtreding
21-01-1989
- Bronpublicatie inwerkingtreding:
16-01-1989, Trb. 1989, 4 (uitgifte: 01-01-1989, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Voorkoming van dubbele belasting
Internationaal belastingrecht / Belastingverdragen
1.
Income derived by a resident of one of the States in respect of professional services or other activities of an independent character shall be taxable only in that State except in the following circumstances, when such income may also be taxed in the other State:
- a)
if he has a fixed base regularly available to him in the other State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other State; or
- b)
if his stay in the other State is for a period or periods amounting to or exceeding in the aggregate 183 days in the fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State.
2.
The term ‘professional services’ includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.