Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Kingdom of the Netherlands: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993U.S. Government Printing Office, 1993 - 137 lappuses |
No grāmatas satura
1.–5. rezultāts no 44.
. lappuse
... Permanent Establishment Article 6. Income from Real Property Article 7. Business Profits Article 8. Shipping and Air Transport Article 9. Associated Enterprises Article 10. Dividends Article 11. Branch Tax 48 49 53 54 56 62 Article 12 ...
... Permanent Establishment Article 6. Income from Real Property Article 7. Business Profits Article 8. Shipping and Air Transport Article 9. Associated Enterprises Article 10. Dividends Article 11. Branch Tax 48 49 53 54 56 62 Article 12 ...
2. lappuse
... permanent establishment or fixed base ( Articles 7 and 15 ) . Similarly , the treaty contains the standard " commercial visitor " exemptions under which residents of one coun- try performing personal services in the other will not be ...
... permanent establishment or fixed base ( Articles 7 and 15 ) . Similarly , the treaty contains the standard " commercial visitor " exemptions under which residents of one coun- try performing personal services in the other will not be ...
3. lappuse
... permanent establish- ment in a third country , and the permanent establishment is both exempt from Dutch tax and subject to special or low taxation be- cause of a " tax haven " regime . On October 13 , 1993 a protocol for this purpose ...
... permanent establish- ment in a third country , and the permanent establishment is both exempt from Dutch tax and subject to special or low taxation be- cause of a " tax haven " regime . On October 13 , 1993 a protocol for this purpose ...
4. lappuse
... permanent home , or an habitual abode in the United States . The U.S. model , by contrast , provides for the other ... permanent establishment shall include only the profits de- rived from the assets or activities of the permanent ...
... permanent home , or an habitual abode in the United States . The U.S. model , by contrast , provides for the other ... permanent establishment shall include only the profits de- rived from the assets or activities of the permanent ...
5. lappuse
... permanent establishment . This is consistent with the U.S. model treaty . ( 10 ) The proposed treaty , like the U.S. model treaty and similar to the present treaty , provides that profits of an enterprise of one treaty country from the ...
... permanent establishment . This is consistent with the U.S. model treaty . ( 10 ) The proposed treaty , like the U.S. model treaty and similar to the present treaty , provides that profits of an enterprise of one treaty country from the ...
Citi izdevumi - Skatīt visu
Bieži izmantoti vārdi un frāzes
alienation amount apply attributable beleggingsinstelling branch profits tax branch tax business profits competent authorities coun country of residence deductible dividend tax double taxation Dutch company Dutch corporation Dutch law Dutch resident Dutch tax earned effectively connected entity establishment or fixed exchange excise tax exemption FIRPTA fixed base foreign corporation foreign person foreign tax credit gain headquarters company income tax treaty independent personal services internal law limitation on benefits Netherlands nonresident nonresident alien payments posed treaty present treaty profit share proposed protocol proposed treaty contains proposed treaty provides purposes reinsurance resi residence country royalties rules source country tax staff understands subject to U.S. tax avoidance taxable taxpayer third country tion trade or business trea treaty benefits treaty country resident U.S. citizens U.S. corporation U.S. income tax U.S. law U.S. model treaty U.S. person U.S. real property U.S. resident U.S. source income U.S. trade U.S. treaties United withholding tax
Populāri fragmenti
30. lappuse - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
48. lappuse - The term shall in any case Include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property.
118. lappuse - Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other...
52. lappuse - For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
131. lappuse - State (other than the business of making or managing investments, unless these activities are banking or insurance activities carried on by a bank or insurance company...
47. lappuse - ... the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character...
57. lappuse - ... income that is treated as effectively connected with the conduct of a US trade or business. The...
51. lappuse - State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment . 3.
42. lappuse - ... means any body corporate or any entity which is treated as a body corporate for tax purposes; f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State...
44. lappuse - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.