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CHAPTER I - Scope of the Arrangement
CHAPTER II - Definitions
CHAPTER III - Taxation of Income
CHAPTER IV - Avoidance of Double Taxation
CHAPTER V - Special Provisions
CHAPTER VI - Final Provisions
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.


Persons Covered

(1) This Arrangement (rijkswet) shall apply to persons who are residents of one or both of the countries (landen).

(2) Notwithstanding the provisions of paragraph (1):

  • (a) a foundation (stichting) which, according to its statutes, is established as a private foundation (stichting particulier fonds) or a trust which is exempt from profit tax (winstbelasting) under sub-paragraph (i) of paragraph (1) of Article 2 of the Profit Tax Ordinance (Landsverordening op de winstbelasting), unless it is designated as a special purpose fund (doelvermogen) under Article 1B of the Profit Tax Ordinance;
  • (b) an Exempt Company (Vrijgestelde Vennootschap) within the meaning of sub-paragraph (f) of paragraph (1) of Article 1A of the Profit Tax Ordinance; and
  • (c) a tax exempt investment institution (vrijgestelde beleggingsinstelling) within the meaning of Article 6a of the Company Tax Act 1969 (Wet op de vennootschapsbelasting 1969);

shall not be entitled to the benefits of Articles 10, 11, 12, paragraph (4) of Article 13 and paragraph (1) of Article 20.

(3) The competent authorities of both countries may determine in consultation whether a resident of a country that falls within a special regulation shall not be entitled to the benefits of this Arrangement.