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 |
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1.5. rezultāts no 38.
. lappuse
... Royalties 68 Article 14. Capital Gains 71 Article 15. Independent Personal Services 76 Article 16. Dependent Personal Services 78 Article 17. Directors ' Fees 78 Article 18. Artistes and Athletes 78 Article 19. Pensions , Annuities ...
... Royalties 68 Article 14. Capital Gains 71 Article 15. Independent Personal Services 76 Article 16. Dependent Personal Services 78 Article 17. Directors ' Fees 78 Article 18. Artistes and Athletes 78 Article 19. Pensions , Annuities ...
. lappuse
... Royalties 131 Article 3. Basis of Taxation 132 Article 4. Methods of Elimination of Double Tax- ation 132 Article 5. Limitation of Benefits 133 Article 6. Exempt Pension Trusts 133 Article 7. Entry Into Force 134 Exchange of Notes 134 ...
... Royalties 131 Article 3. Basis of Taxation 132 Article 4. Methods of Elimination of Double Tax- ation 132 Article 5. Limitation of Benefits 133 Article 6. Exempt Pension Trusts 133 Article 7. Entry Into Force 134 Exchange of Notes 134 ...
2. lappuse
... royalties received by a resident of one country from sources within the other country are to be taxed by the source country on a restricted basis or not at all ( Articles 10 , 12 , and 13 ) . In situations where the country of source ...
... royalties received by a resident of one country from sources within the other country are to be taxed by the source country on a restricted basis or not at all ( Articles 10 , 12 , and 13 ) . In situations where the country of source ...
3. lappuse
... royalties attributable to a 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 ...
... royalties attributable to a 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 ...
7. lappuse
... royalties articles in the present treaty and the U.S. and OECD model treaties , the royalties article in the proposed treaty has a general limitation on the taxation of royalties paid by residents of the other country . The effect of ...
... royalties articles in the present treaty and the U.S. and OECD model treaties , the royalties article in the proposed treaty has a general limitation on the taxation of royalties paid by residents of the other country . The effect of ...
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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.