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
Article 3 Avoidance of double taxation
Geldend
Geldend vanaf 25-11-2018
- Bronpublicatie:
06-01-2008, Trb. 2008, 59 (uitgifte: 03-04-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
25-11-2018
- Bronpublicatie inwerkingtreding:
15-11-2018, Trb. 2018, 198 (uitgifte: 15-11-2018, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Vervoersrecht / Luchtvervoer
1.
Income and profits derived from the operation of aircraft in international air traffic by an 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 air traffic by an 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 enterprise of a Contracting State from the operation of aircraft in international air traffic includes interest derived from bank deposits directly connected with and incidental to the operation of aircraft in international air traffic.
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.
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 enterprise of the other Contracting State which operates air services in international air traffic shall be exempted from tax in the first-mentioned State with respect to his remuneration received from the afore-mentioned enterprise for such a purpose for a period of three years.