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 8 Shipping and air transport
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.
Profits from the operation of ships or aircraft 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 of a shipping enterprise 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.
For the purposes of this Article, profits derived from the operation in international traffic of ships and aircraft include profits derived from the rental on a bare boat basis of ships and aircraft if operated in international traffic if such rental profits are an occasional source of income in relation to the profits described in paragraph 1.
4.
The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.