Convention between the Kingdom of the Netherlands and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income:artikel 15

Convention between the Kingdom of the Netherlands and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Article 15 Independent Personal Services

Geldend

Documentgegevens:

Geldend vanaf 31-12-1993

Bronpublicatie:: 18-12-1992, Trb. 1993, 77 (uitgifte: 07-06-1993, kamerstukken/regelingnummer: -)
Inwerkingtreding: 31-12-1993
Bronpublicatie inwerkingtreding:: 31-12-1993, Trb. 1993, 202 (uitgifte: 01-01-1993, kamerstukken/regelingnummer: -)
Vakgebied(en): Internationaal belastingrecht (V)
Internationaal belastingrecht / Voorkoming van dubbele belasting
Internationaal belastingrecht / Belastingverdragen

1.

Income derived by an individual who is a resident of one of the States from the performance of personal services in an independent capacity shall be taxable only in that State, unless such services are not performed in that State and the income derived therefrom is attributable to a fixed base regularly available to the individual in the other State for the purpose of performing his activities.

2.

The term ‘personal services in an independent capacity’ includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.