Einde inhoudsopgave
Convention between the Government of the Kingdom of the Netherlands and the Government of the Kingdom of Saudi Arabia for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income
Article 14 Independent personal services
Geldend
Geldend vanaf 01-12-2010
- Redactionele toelichting
Gecorrigeerd via een rectificatie (Trb. 2019, 166).
- Bronpublicatie:
13-10-2008, Trb. 2008, 214 (uitgifte: 17-12-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
01-12-2010
- Bronpublicatie inwerkingtreding:
23-12-2010, Trb. 2010, 329 (uitgifte: 23-12-2010, 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 except in the following circumstances when such income may also be taxed in the other Contracting State:
- a)
if he has a fixed base regularly available to him in the other Contracting State for 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 Contracting State; or
- b)
if he is present in the other Contracting State for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending 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.