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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.

ARTICLE 22

Anti-Abuse Provisions

(1) The provisions of this Arrangement shall not preclude the application of rules laid down in the tax laws of each of the countries for the prevention of fraud, abuse and improper use.

(2) Notwithstanding the provisions of paragraph (1), the provisions of sub-paragraph (b) of paragraph (3) of Article 17 of the Company Tax Act 1969 (Wet op de vennootschapsbelasting 1969), shall not be applicable in respect of an interest (belang) held by a company which is a resident of St. Maarten in a company which is a resident of the Netherlands, where the first-mentioned company in respect of such interest qualifies for the benefits of paragraph 3 of Article 10, whether or not in conjunction with paragraph (5) of Article 10.