Home Nonfiction 10 • Download Model Income Tax Treaties by Kees van Raad (auth.), Kees van Raad (eds.) PDF

Download Model Income Tax Treaties by Kees van Raad (auth.), Kees van Raad (eds.) PDF

By Kees van Raad (auth.), Kees van Raad (eds.)

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Extra resources for Model Income Tax Treaties

Example text

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 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.

Where subparagraph c) applies and subparagraphs a) and b) do not apply, the tax shall be subject to the limitations of paragraph 2. Article 11 Article 11 INTEREST INTEREST 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed ...

2. However, such dividends may [] be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but[] the tax so charged shall not exceed: 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: 34 UN USA 2.

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