Einde inhoudsopgave
Convention between the Kingdom of the Netherlands and Barbados for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
Article 14 Independent personal services
Geldend
Geldend vanaf 12-07-2007
- Bronpublicatie:
28-11-2006, Trb. 2006, 269 (uitgifte: 21-12-2006, kamerstukken/regelingnummer: -)
- Inwerkingtreding
12-07-2007
- Bronpublicatie inwerkingtreding:
05-07-2007, Trb. 2007, 118 (uitgifte: 01-01-2007, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Belastingverdragen
1.
Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities or he is present in that other State for a period or periods exceeding in the aggregate 183 days in the fiscal year concerned.
If he has such a fixed base or remains in that other State for the aforesaid period or periods, the income may be taxed in the other State but only so much of it as is attributable to that fixed base or is derived from his activities performed in that other State during the aforesaid period or periods.
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.