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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 2

Taxes Covered by the Convention

(1) This Convention shall apply to taxes on income and on capital imposed on behalf of each of the States or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are, in particular:

  • (a) in the case of the Netherlands:
    • (i) income tax (de inkomstenbelasting);
    • (ii) wages tax (de loonbelasting);
    • (iii) company tax (de vennootschapsbelasting);
    • (iv) dividend tax (de dividendbelasting);
    • (v) capital tax (de vermogensbelasting);
  • (hereinafter referred to as "Netherlands tax");
  • (b) in the case of Suriname:
    • (i) income tax (de inkomstenbelasting);
    • (ii) dividend tax (de dividendbelasting);
    • (iii) capital tax (de vermogensbelasting);
  • (hereinafter referred to as "Surinamese tax").

(4) This Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed in addition to, or in place of, the existing taxes. The competent authorities of the States shall notify each other of any substantial changes which have been made in their respective taxation laws.