Einde inhoudsopgave
Convention between The Kingdom of The Netherlands and The Republic of Azerbaijan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital
Article 22 Capital
Geldend
Geldend vanaf 18-12-2009
- Bronpublicatie:
22-09-2008, Trb. 2008, 202 (uitgifte: 31-10-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
18-12-2009
- Bronpublicatie inwerkingtreding:
05-02-2010, Trb. 2010, 44 (uitgifte: 05-02-2010, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Belastingverdragen
1.
Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
2.
Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
3.
Capital of an enterprise of a Contracting State represented by ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft, shall be taxable only in that Contracting State.
4.
All other elements of capital of a resident of a Contracting State shall be taxable only in that State.