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 87.
2. lappuse
... 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 retains the right under the proposed treaty to tax income ...
... 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 retains the right under the proposed treaty to tax income ...
3. lappuse
... income . The Dutch law or proto- col to be adopted must , under the terms of the proposed treaty , deal with the situation where a Dutch enterprise derives foreign source interest or royalties attributable to a permanent establish- ment ...
... income . The Dutch law or proto- col to be adopted must , under the terms of the proposed treaty , deal with the situation where a Dutch enterprise derives foreign source interest or royalties attributable to a permanent establish- ment ...
5. lappuse
... source country at a rate no greater than 5 percent . The present treaty has a simi- lar rate schedule , but in order to qualify for the direct dividend withholding rate , a higher ownership threshold must be met ( either 25 percent ...
... source country at a rate no greater than 5 percent . The present treaty has a simi- lar rate schedule , but in order to qualify for the direct dividend withholding rate , a higher ownership threshold must be met ( either 25 percent ...
6. lappuse
... source country taxation on interest ( including the branch level tax on excess interest deductions ) , the proposed treaty ex- pressly allows the United States to impose withholding tax at the dividend rate on income from any ...
... source country taxation on interest ( including the branch level tax on excess interest deductions ) , the proposed treaty ex- pressly allows the United States to impose withholding tax at the dividend rate on income from any ...
7. lappuse
... source income and , had the payor been a resident of any other country , would have been subject to a U.S. gross - basis tax . One of the exceptions allows the United States to impose tax on a royalty in the case of back- to - back ...
... source income and , had the payor been a resident of any other country , would have been subject to a U.S. gross - basis tax . One of the exceptions allows the United States to impose tax on a royalty in the case of back- to - back ...
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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.