Einde inhoudsopgave
Convention between the Kingdom of the Netherlands and the Republic of Ghana for the Elimination of Double Taxation with respect to Taxes on Income and on Capital Gains and the Prevention of Tax Evasion and Avoidance
Article 14 Independent personal services
Geldend
Geldend vanaf 12-11-2008
- Bronpublicatie:
10-03-2008, Trb. 2008, 109 (uitgifte: 23-05-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
12-11-2008
- Bronpublicatie inwerkingtreding:
27-11-2008, Trb. 2008, 217 (uitgifte: 01-01-2008, 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, unless:
- a)
he has a fixed base regularly available to him in the other Contracting State for the purpose of 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)
his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate of nine months 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 Contracting 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.