Einde inhoudsopgave
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 8 Shipping and air transport
Geldend
Geldend vanaf 25-12-2009
- Bronpublicatie:
24-04-2008, Trb. 2008, 112 (uitgifte: 27-05-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
25-12-2009
- Bronpublicatie inwerkingtreding:
13-01-2010, Trb. 2010, 11 (uitgifte: 13-01-2010, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Belastingverdragen
1.
Profits from the operation of ships in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
2.
If the place of effective management is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.
3.
The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency, but only so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.
4.
The provisions of this Agreement shall not affect the application of the Convention between the Government of the Kingdom of the Netherlands and the Government of the State of Qatar for the Avoidance of Double Taxation on Income and Profits derived from International Air Transport, signed at Doha on the 6th of January 2008.