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2010-12-01 | BWBV0006082 | Overeenkomst tussen het Koninkrijk der Nederlanden en de Tsjechoslowaakse Socialistische 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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Coornhert 2010-12-01 12:00:00 +00:00
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verdrag/overeenkomst-tussen-het-koninkrijk-der-nederlanden-en-de-tsjechoslowaakse-social/BWBV0006082/README.md
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@ -266,13 +266,20 @@ Notwithstanding the provisions of Articles 15 and 16, income derived by public e
### Artikel 19
Subject to the provisions of paragraph 1 of Article 20, pensions and other similar remuneration paid to a resident of one of the States in consideration of past employment shall be taxable only in that State.
Subject to the provisions of paragraph 2 of Article 20, pensions and other similar remuneration paid to a resident of one of the States in consideration of past employment shall be taxable only in that State.
### Artikel 20
**1.** Remuneration, including pensions, paid by, or out of funds created by, one of the States or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or local authority thereof in the discharge of functions of a governmental nature may be taxed in that State.
**1.** a) Salaries, wages and other similar remuneration paid by one of the States or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority may be taxed in that State.
b) However, such salaries, wages and other similar remuneration shall be taxable only in the other State if the services are rendered in that State and the individual is a resident of that State who:
**2.** However, the provisions of Articles 16, 17 and 19 shall apply to remuneration or pensions in respect of services rendered in connection with any trade or business carried on by one of the States or a political subdivision or a local authority thereof.
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the purpose of rendering the services.
**2.** a) Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration paid by, or out of funds created by, one of the States or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority may be taxed in that State.
b) However, such pensions and other similar remuneration shall be taxable only in the other State if the individual is a resident of, and a national of, that State.
**3.** The provisions of Articles 16, 17 and 19 shall apply to salaries, wages, pensions, and other similar remuneration in respect of services rendered in connection with a business carried on by a State or a political subdivision or a local authority thereof.
### Artikel 21
@ -307,7 +314,7 @@ It is agreed that double taxation shall be avoided in the following manner:
A. In the case of the Netherlands:
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 Czechoslovakia.
2. Without prejudice to the application of the provisions concerning the compensation of losses in the unilateral regulations for the avoidance of double taxation the Netherlands shall allow a deduction from the amount of tax computed in conformity with paragraph 1 of this Article equal to such part of that tax which bears the same proportion to the aforesaid tax, as the part of the income or capital which is included in the basis mentioned in the first paragraph of this Article and may be taxed in Czechoslovakia according to Articles 6 and 7, paragraph 7 of Article 10, paragraph 3 of Article 11, paragraph 5 of Article 12, paragraphs 1 and 2 of Article 14, Article 15, paragraph 1 of Article 16, paragraph 1 of Article 17, Article 20, paragraphs 1 and 2 of Article 24, of this Convention bears to the total income or capital which forms the basis mentioned in paragraph 1 of this Article.
2. Without prejudice to the application of the provisions concerning the compensation of losses in the unilateral regulations for the avoidance of double taxation the Netherlands shall allow a deduction from the amount of tax computed in conformity with paragraph 1 of this Article equal to such part of that tax which bears the same proportion to the aforesaid tax, as the part of the income or capital which is included in the basis mentioned in the first paragraph of this Article and may be taxed in Czechoslovakia according to Articles 6 and 7, paragraph 7 of Article 10, paragraph 3 of Article 11, paragraph 5 of Article 12, paragraphs 1 and 2 of Article 14, Article 15, paragraph 1 of Article 16, paragraph 1 of Article 17, paragraphs 1 (subparagraph a) and 2 (subparagraph a) of Article 20, paragraphs 1 and 2 of Article 24, of this Convention bears to the total income or capital which forms the basis mentioned in paragraph 1 of this Article.
3. Further the Netherlands shall allow a deduction from the tax computed in accordance with the preceding paragraphs of this Article with respect to the items of income which may be taxed in Czechoslovakia according to paragraph 2 of Article 10, paragraph 2 of Article 12, paragraph 5 of Article 14, and Article 18, and are included in the basis mentioned in paragraph 1 of this Article. The amount of this deduction shall be the lesser of the following amounts:
a) the amount equal to the Czechoslovak tax;