Convention between the Government of the Kingdom of the Netherlands and the Government
of the State of Qatar for the avoidance of double taxation on income and profits derived
from international air transport
[Treedt in werking per 25-11-2018]
The Government of the Kingdom of the Netherlands
and
the Government of the State of Qatar,
Desiring to conclude a convention for the avoidance of double taxation on income and
profits from international air transport,
Article 1. Taxes covered
[Treedt in werking per 25-11-2018]
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2 The Convention shall apply also to any identical or substantially similar taxes which
are imposed after the date of signature of the Convention in addition to, or in place
of, the existing taxes. The competent authorities of the Contracting States shall
notify each other of any substantial changes which have been made in the taxes referred
to in this Article.
Article 2. Definitions
[Treedt in werking per 25-11-2018]
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2 As regards the application of the Convention at any time by a Contracting State, any
term not defined therein shall, unless the context otherwise requires, have the meaning
that it has at that time under the law of that State for the purposes of the taxes
to which the Convention applies, any meaning under the applicable tax laws of that
State prevailing over a meaning given to the term under other laws of that State.
Article 3. Avoidance of double taxation
[Treedt in werking per 25-11-2018]
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2 Income and profits derived from the alienation of aircraft operated in international
air traffic by an enterprise of a Contracting State and movable property pertaining
to the operation of such aircraft shall be exempted from tax in the other Contracting
State, irrespective of the manner in which it is levied.
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3 For the purposes of this Article, income and profits derived by an enterprise of a
Contracting State from the operation of aircraft in international air traffic includes
interest derived from bank deposits directly connected with and incidental to the
operation of aircraft in international air traffic.
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5 An individual who acquires in one of the Contracting States technical, professional
or business experience with respect to the operation of aircraft as an employee of
an enterprise of the other Contracting State which operates air services in international
air traffic shall be exempted from tax in the first-mentioned State with respect to
his remuneration received from the afore-mentioned enterprise for such a purpose for
a period of three years.
Article 4. Refund
[Treedt in werking per 25-11-2018]
Where tax has been levied and collected by a Contracting State contrary to the provisions
of this Convention, applications for the refund of tax have to be lodged with the
competent authority of that State within a period of three years after the expiration
of the calendar year in which the tax has been levied and the tax so collected shall
be refunded within six months from the date of such application.
Article 5. Mutual agreement procedure
[Treedt in werking per 25-11-2018]
Article 6. Territorial extension
[Treedt in werking per 25-11-2018]
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1 As regards the Kingdom of the Netherlands, this Convention may be extended, either
in its entirety or with any necessary modifications, to either the Netherlands Antilles
or Aruba or both countries, if the country concerned imposes taxes substantially similar
in character to those to which this Convention applies. Any such extension shall take
effect from such date and be subject to such modifications and conditions, including
conditions as to termination, as may be specified and agreed in notes to be exchanged
through diplomatic channels.
Article 7. Entry into force
[Treedt in werking per 25-11-2018]
Article 8. Termination
[Treedt in werking per 25-11-2018]
This Convention shall remain in force indefinitely, but either Contracting State may
terminate it by giving notice of termination through diplomatic channels, at least
six months before the end of any calendar year after the fifth year following that
of the entry into force. In such event this Convention shall cease to have effect
for taxable years beginning after the end of the calendar year in which the notice
of termination has been given.