Convention between the Kingdom of the Netherlands and the Republic of Poland for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance:artikel 15

Convention between the Kingdom of the Netherlands and the Republic of Poland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income

Article 15 Dependent personal services

Geldend

Documentgegevens:

Geldend vanaf 18-03-2003

Bronpublicatie:: 13-02-2002, Trb. 2002, 86 (uitgifte: 24-04-2002, kamerstukken/regelingnummer: -)
Inwerkingtreding: 18-03-2003
Bronpublicatie inwerkingtreding:: 21-03-2003, Trb. 2003, 39 (uitgifte: 21-03-2003, kamerstukken/regelingnummer: -)
Vakgebied(en): Internationaal belastingrecht (V)
Internationaal belastingrecht / Voorkoming van dubbele belasting
Internationaal belastingrecht / Belastingverdragen

1.

Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

2.

Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:

a): the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned, and
b): the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and
c): the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.

3.

Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft or a boat engaged in inland waterways transport operated in international traffic, shall be taxable only in that State.