Double Taxation Avoidance Agreement With Netherlands

3. The competent authorities of the States shall endeavour to eliminate, by mutual agreement, any difficulty or doubt as to the interpretation or application of the Convention. They may also consult each other on the elimination of double taxation in cases not provided for in the Convention. If you need more information about the Dutch tax system or professional audit and accounting services in Holland, please contact our accountants. 2. profits from the sale of movable property which forms part of the commercial assets of a permanent establishment disposed of an enterprise of one of the States of the other State or of movable assets which relate to a fixed base at the disposal of a person established in one of the States of the other State for the provision of independent personal services; including profits from the disposal of such a permanent establishment (alone or with the enterprise as a whole) or from such a fixed base may be taxed in that other State. (2) Articles 15, 16 and 18 shall apply to remuneration and pensions for services provided in the course of an activity carried out by one of the States, a political subdivision or a territorial authority. 3. An enterprise of one Of the States shall not be considered to be an enterprise having a permanent establishment in the other State only because it operates in that other State through a broker, a general commission agent or another independent representative, provided that such persons are acting in the course of their ordinary activities. However, where the activities of such an agent are wholly or almost entirely intended for the undertaking of that undertaking, he shall not be regarded as an independent representative within the meaning of this paragraph if it is demonstrated that the transactions between the representative and the undertaking were not carried out under the conditions of the status of third party. Special rules for frontier workers are contained in the following double taxation conventions: 6.

Paragraphs 1 and 2 shall not apply where the beneficial owner of the dividends, who is established in one of the States, in the other State in which the company which paid the dividends is established, operates through a permanent establishment or provides independent personal services in that other State from a fixed place of business in that State; and the holding for which the dividends are paid is effectively linked to that permanent establishment or to the fixed base. . . .