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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 32

Transitional Rules in respect of individuals holding a substantial interest - aanmerkelijk belang

(1) Where an individual referred to in paragraph (14) of Article 10 and paragraph (5) of Article 13 already was a resident of the other country before the time of submission of the Royal Message regarding this Arrangement, the ten-year period referred to in those Articles shall be reduced to a period of five years.

(2) Where the provisions of paragraph (1) apply in respect of paragraph (14) of Article 10, the tax payable on taxable income from a substantial interest (belastbare inkomen uit aanmerkelijk belang) referred to in Article 7.5 of the Income Tax Act 2001 (Wet op de inkomstenbelasting 2001) may not exceed 15% of such income.