2009-05-22 | BWBV0001353 | Verdrag tussen het Koninkrijk der Nederlanden en de Republiek Estland 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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@ -359,16 +359,17 @@ Payments which a student, or an apprentice or trainee, who is or was immediately
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In Estonia double taxation shall be avoided as follows:
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a) Where a resident of Estonia derives income which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, Estonia shall, subject to the provisions of sub-paragraphs b) and c) exempt such income from tax.
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b) Where a resident of Estonia derives or owns captial which in accordance with the provisions of:
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b) Where a resident of Estonia derives income or owns capital which in accordance with the provisions of:
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(i) subparagraph b) of paragraph 2 of Article 10; or
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(iii) paragraph 2 of Articles 11 or 12; or
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(iii) paragraphs 1 or 2 of Article 23
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(ii) paragraph 2 of Articles 11 or 12; or
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(iii) paragraphs 1 or 2 of Article 17; or
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(iv) paragraphs 1 or 2 of Article 23
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may be taxed in the Netherlands, Estonia shall allow as a deduction from the tax on the income or capital of that resident an amount equal to the tax paid in the Netherlands. Such deduction in either case shall not, however, exceed the part of the income or capital tax in Estonia as computed before the deduction is given, which is attributable to the income or the capital which may be taxed in the Netherlands.
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c) Where in accordance with any provision of the Convention income derived by a resident of Estonia is exempt from tax in Estonia, Estonia may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
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For the purposes of this paragraph, the taxes referred to in paragraphs 3a) and 4 of Article 2, other than the capital tax, shall be considered taxes on income.
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For the purposes of this paragraph, the taxes referred to in paragraph 3, subparagraph a, and paragraph 4 of Article 2, other than the capital tax, shall be considered taxes on income.
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## Hoofdstuk VI. SPECIAL PROVISIONS
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