2006-07-01 | BWBV0002791 | Overeenkomst tussen het Koninkrijk der Nederlanden en de Helleense Republiek tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen en naar het vermogen
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@ -333,8 +333,6 @@ A. In the case of the Netherlands:
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1. The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income or capital which, according to the provisions of this Convention, may be taxed in Greece.
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2. However, where a resident of the Netherlands derives items of income or owns capital which according to Article 6, Article 7, paragraph 4 of Article 10, paragraph 4 of Article 11, paragraph 4 of Article 12, paragraph 1 and 2 of Article 14, Article 15, paragraph 1 of Article 16, paragraph 1 of Article 17, Article 20, paragraph 2 of Article 23 and paragraphs 1 and 2 of Article 24 of this Convention may be taxed in Greece and are included in the basis referred to in paragraph 1, the Netherlands shall exempt such items by allowing a reduction of its tax. This reduction shall be computed in conformity whith the provisions of Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the total amount of the items of income which are exempt from Netherlands tax under those provisions.
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3. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 (b) of Article 10, paragraph 2 of Article 11, paragraph 2 of Article 12, paragraph 5 of Article 14, paragraph 3 of Article 16, Article 18 and paragraph 2 of Article 19 of this Convention may be taxed in Greece to the extent that these items are included in the basis referred to in paragraph 1. The amount of this deduction shall be equal to the tax paid in Greece on these items of income, provided that in the case of dividends not more than 15 percent of the gross amount thereof is taken into account, but shall not exceed the amount of the reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
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4. Where, by reason of special incentive measures designed to promote economic development in Greece, the Greek tax actually levied on interest arising in Greece is lower than the tax Greece may levy according to paragraph 2 of Article 11, then, for the purposes of the preceding paragraph, the tax paid in Greece on such interest shall be deemed to be 10 percent of the gross amount thereof.
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5. For the purposes of paragraph 3 above the tax paid in Greece on royalties arising in Greece, to which sub-paragraph b of paragraph 2 of Article 12 applies, shall be deemed to be 10 percent of the gross amount thereof.
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B. In the case of Greece:
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1. Greece, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income or capital which, according to the provisions of this Convention, may be taxed in the Netherlands.
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