Common use of METHODS FOR ELIMINATION OF DOUBLE TAXATION Clause in Contracts

METHODS FOR ELIMINATION OF DOUBLE TAXATION. The method of elimination of double taxation will be as follows: 1. In case of the Netherlands: (a) when the Netherlands imposes a tax on its residents, it may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this Convention, may or shall be only taxable in the Kingdom of Saudi Arabia. (b) However, where a resident of the Netherlands derives items of income which according to Article 6, Article 7, paragraph 4 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, paragraph 1 of Article 14, paragraph 1 of Article 15, paragraphs 1 (a) and 2 (a) of Article 19 and paragraph 2 of Article 22 of this Convention may be taxed in the Kingdom of Saudi Arabia and are included in the basis referred to in paragraph 1 (a), the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of the Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the amount of the items of income which are exempt from Netherlands tax under those provisions. (c) Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 (b) of Article 10, paragraph 3 of Article 13, Article 16, paragraphs 1 and 2 of Article 17 and paragraph 3 of Article 18 of this Convention may be taxed in the Kingdom of Saudi Arabia to the extent that these items are included in the basis referred to in paragraph 1 (a). The amount of this deduction shall be equal to the tax paid in the Kingdom of Saudi Arabia on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provide so, not exceed the amount of the deduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of the Netherlands law for the avoidance of double taxation. This paragraph shall not restrict allowance now or hereafter accorded by the provisions of the Netherlands law for the avoidance of double taxation, but only as far as the calculation of the amount of the deduction of Netherlands tax is concerned with respect to the aggregation of income from more than one country and the carry forward of the tax paid in the Kingdom of Saudi Arabia on the said items of income to subsequent years. (d) Notwithstanding the provisions of paragraph 1 (b) of this Article, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in the Kingdom of Saudi Arabia on items of income which according to Article 7, paragraph 4 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12 and paragraph 2 of Article 22 of this Convention may be taxed in the Kingdom of Saudi Arabia to the extent that these items are included in the basis referred to in paragraph 1 (a), insofar as the Netherlands under the provisions of the Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 1 (c) of this Article shall apply accordingly. 2. In case of the Kingdom of Saudi Arabia: (a) where a resident of the Kingdom of Saudi Arabia derives income which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, the Kingdom of Saudi Arabia shall, subject to the provisions of paragraph 2 (b) of this Article, exempt such income from tax. (b) where a resident of the Kingdom of Saudi Arabia derives items of income which, in accordance with the provisions of Articles 10, 11, 12 and paragraphs 3 and 4 of Article 13 may be taxed in the Netherlands, the Kingdom of Saudi Arabia shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Netherlands. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from the Netherlands. (c) In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice to the provisions of the Zakat collection regime as regards Saudi nationals.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. The method of elimination of 1. In Vietnam, double taxation will shall be eliminated as follows: Where a resident of Vietnam derives income, profits or gains which under the law of the Netherlands and in accordance with this Agreement may be taxed in the Netherlands, Vietnam shall allow as a credit against its tax on the income, profits or gains an amount equal to the tax paid in the Netherlands. The amount of credit, however, shall not exceed the amount of Vietnamese tax on that income, profits or gains computed in accordance with the taxation laws and regulations of Vietnam. 2. In the Netherlands, double taxation shall be eliminated as follows: 1. In case of the a. The Netherlands: (a) , when the Netherlands imposes a imposing tax on its residents, it may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this ConventionAgreement, may or shall be only taxable taxed in the Kingdom of Saudi Arabia.Vietnam; (b) b. However, where a resident of the Netherlands derives items of income which according to Article 6, Article 7, paragraph 4 6 of Article 10, paragraph 5 6 of Article 11, paragraph 4 5 of Article 12, paragraphs 1 and 2 of Article 13, paragraph 1 of Article 14, paragraph paragraphs 1 and 3 of Article 15, paragraphs 1 (asubparagraph a.), 2 (subparagraph a.) and 2 (a) 4 of Article 19 and paragraph 2 of Article 22 of this Convention Agreement may be taxed in the Kingdom of Saudi Arabia Vietnam and are included in the basis referred to in paragraph 1 subparagraph (a), the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of the Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the total amount of the items of income which are exempt from Netherlands tax under those provisions.; (c) c. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 (b) of Article 10, paragraph 3 2 of Article 11, paragraph 2 of Article 12, paragraphs 4 and 6 of Article 13, Article 16, paragraphs 1 and 2 of Article 17 and paragraph 3 2 of Article 18 of this Convention Agreement may be taxed in the Kingdom of Saudi Arabia Vietnam to the extent that these items are included in the basis referred to in paragraph 1 subparagraph (aa.). The amount of this deduction shall be equal to the tax paid in the Kingdom of Saudi Arabia Vietnam on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provide so, shall not exceed the amount of the deduction reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of the Netherlands law for the avoidance of double taxation. This paragraph shall not restrict allowance now or hereafter accorded ; d. Where, by reason of the relief given under the provisions of the Netherlands law Vietnamese laws for the avoidance purpose of double taxationencouraging investment in Vietnam, but only as far as or by the calculation of relief given under the Agreement, the Vietnamese tax actually levied on interest arising in Vietnam or on royalties arising in Vietnam is lower than 10 per cent, the amount of the deduction of Netherlands tax is concerned with respect to the aggregation of income from more than one country and the carry forward of the tax paid in Vietnam on such interest and royalties shall be deemed to have been paid at the Kingdom rate of Saudi Arabia on 10 per cent. However, if the said items of income general tax rates under Vietnamese laws applicable to subsequent years. (d) Notwithstanding the provisions of paragraph 1 (b) afore-mentioned interest and royalties are reduced below those mentioned in this subparagraph, these lower rates shall apply for the purposes of this Article, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in the Kingdom of Saudi Arabia on items of income which according to Article 7, paragraph 4 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12 and paragraph 2 of Article 22 of this Convention may be taxed in the Kingdom of Saudi Arabia to the extent that these items are included in the basis referred to in paragraph 1 (a), insofar as the Netherlands under the provisions of the Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of incomesubparagraph. For the computation of this deduction the provisions of paragraph 1 (c) of this Article shall apply accordingly. 2. In case of the Kingdom of Saudi Arabia: (a) where a resident of the Kingdom of Saudi Arabia derives income which, in accordance with the The provisions of this Convention, subparagraph shall only apply for a period of ten years after the date on which the Agreement entered into force. This period may be taxed in extended by mutual agreement between the Netherlands, the Kingdom of Saudi Arabia shall, subject to the provisions of paragraph 2 (b) of this Article, exempt such income from taxcompetent authorities. (b) where a resident of the Kingdom of Saudi Arabia derives items of income which, in accordance with the provisions of Articles 10, 11, 12 and paragraphs 3 and 4 of Article 13 may be taxed in the Netherlands, the Kingdom of Saudi Arabia shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Netherlands. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from the Netherlands. (c) In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice to the provisions of the Zakat collection regime as regards Saudi nationals.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. The method of elimination of double taxation will be as follows: 1. In case of the The Netherlands: (a) , when the Netherlands imposes a imposing tax on its residents, it may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this ConventionAgreement, may be taxed or shall be taxable only taxable in the Kingdom of Saudi ArabiaHong Kong Special Administrative Region. (b) 2. However, where a resident of the Netherlands derives items of income which according to paragraphs 1, 3 and 4 of Article 6, paragraph 1 of Article 7, paragraph 4 7 of Article 10, paragraph 5 4 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, paragraph paragraphs 1 and 3 of Article 14, paragraph 1 of Article 15, paragraphs 1 (subparagraph (a)) and 2 (subparagraph (a)) of Article 19 18 and paragraph 2 of Article 22 20 of this Convention Agreement may be taxed or shall be taxable only in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region and are included in the basis referred to in paragraph 1 (a)1, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of the Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the amount of the items of income which are exempt from Netherlands tax under those provisions. (c) 3. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph paragraphs 2 (b) and 9 of Article 10, paragraph 3 2 of Article 12, paragraphs 4 and 6 of Article 13, Article 1615, paragraphs 1 and 2 of Article 16, paragraphs 1, 2 and 6 of Article 17 and paragraph 3 of Article 18 20 of this Convention Agreement may be taxed in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region to the extent that these items are included in the basis referred to in paragraph 1 (a)1. The amount of this deduction shall be equal to the tax paid in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provide so, not exceed the amount of the deduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of the Netherlands law for the avoidance of double taxation. This paragraph shall not restrict allowance now or hereafter accorded by the provisions of the Netherlands law for the avoidance of double taxation, but only as far as the calculation of the amount of the deduction of Netherlands tax is concerned with respect to the aggregation of income from more than one country and the carry forward of the tax paid in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region on the said items of income to subsequent years. (d) 4. Notwithstanding the provisions of paragraph 1 (b) of this Article2, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region on items of income which according to paragraph 1 of Article 7, paragraph 4 7 of Article 10, paragraph 5 4 of Article 11, paragraph 4 of Article 12 and paragraph 2 of Article 22 20 of this Convention Agreement may be taxed in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region to the extent that these items are included in the basis referred to in paragraph 1 (a)1, insofar as the Netherlands under the provisions of the Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 1 (c) 3 of this Article shall apply accordingly. 25. In case of the Kingdom of Saudi Arabia: (a) where a resident of the Kingdom of Saudi Arabia derives income which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, the Kingdom of Saudi Arabia shallHong Kong Special Administrative Region, subject to the provisions of paragraph 2 the laws of the Hong Kong Special Administrative Region relating to the allowance of a credit against Hong Kong Special Administrative Region tax of tax paid in a jurisdiction outside the Hong Kong Special Administrative Region (b) which shall not affect the general principle of this Article), exempt such Netherlands tax paid under the laws of the Netherlands and in accordance with this Agreement, whether directly or by deduction, in respect of income from tax. (b) where derived by a person who is a resident of the Kingdom Hong Kong Special Administrative Region from sources in the Netherlands, shall be allowed as a credit against Hong Kong Special Administrative Region tax payable in respect of Saudi Arabia derives items that income, provided that the credit so allowed does not exceed the amount of Hong Kong Special Administrative Region tax computed in respect of that income which, in accordance with the provisions of Articles 10, 11, 12 and paragraphs 3 and 4 of Article 13 may be taxed in the Netherlands, the Kingdom of Saudi Arabia shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Netherlands. Such deduction shall not, however, exceed that part laws of the tax, as computed before the deduction is given, which is attributable to such items of income derived from the Netherlands. (c) In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice to the provisions of the Zakat collection regime as regards Saudi nationals.Hong Kong Special Administrative Region. Chapter V

METHODS FOR ELIMINATION OF DOUBLE TAXATION. The method of elimination of double taxation will be as follows: 1. In case of the The Netherlands: (a) , when the Netherlands imposes a imposing tax on its residents, it may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this ConventionAgreement, may be taxed or shall be taxable only taxable in the Kingdom of Saudi ArabiaHong Kong Special Administrative Region. (b) 2. However, where a resident of the Netherlands derives items of income which according to paragraphs 1, 3 and 4 of Article 6, paragraph 1 of Article 7, paragraph 4 7 of Article 10, paragraph 5 4 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, paragraph paragraphs 1 and 3 of Article 14, paragraph 1 of Article 15, paragraphs 1 (subparagraph (a)) and 2 (subparagraph (a)) of Article 19 18 and paragraph 2 of Article 22 20 of this Convention Agreement may be taxed or shall be taxable only in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region and are included in the basis referred to in paragraph 1 (a)1, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of the Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the amount of the items of income which are exempt from Netherlands tax under those provisions. (c) 3. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph paragraphs 2 (b) and 9 of Article 10, paragraph 3 2 of Article 12, paragraphs 4 and 6 of Article 13, Article 1615, paragraphs 1 and 2 of Article 16, paragraphs 1, 2 and 6 of Article 17 and paragraph 3 of Article 18 20 of this Convention Agreement may be taxed in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region to the extent that these items are included in the basis referred to in paragraph 1 (a)1. The amount of this deduction shall be equal to the tax paid in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provide so, not exceed the amount of the deduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of the Netherlands law for the avoidance of double taxation. This paragraph shall not restrict allowance now or hereafter accorded by the provisions of the Netherlands law for the avoidance of double taxation, but only as far as the calculation of the amount of the deduction of Netherlands tax is concerned with respect to the aggregation of income from more than one country and the carry forward of the tax paid in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region on the said items of income to subsequent years. (d) 4. Notwithstanding the provisions of paragraph 1 (b) of this Article2, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region on items of income which according to paragraph 1 of Article 7, paragraph 4 7 of Article 10, paragraph 5 4 of Article 11, paragraph 4 of Article 12 and paragraph 2 of Article 22 20 of this Convention Agreement may be taxed in the Kingdom of Saudi Arabia Hong Kong Special Administrative Region to the extent that these items are included in the basis referred to in paragraph 1 (a)1, insofar as the Netherlands under the provisions of the Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 1 (c) 3 of this Article shall apply accordingly. 25. In case of the Kingdom of Saudi Arabia: (a) where a resident of the Kingdom of Saudi Arabia derives income which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, the Kingdom of Saudi Arabia shallHong Kong Special Administrative Region, subject to the provisions of paragraph 2 the laws of the Hong Kong Special Administrative Region relating to the allowance of a credit against Hong Kong Special Administrative Region tax of tax paid in a jurisdiction outside the Hong Kong Special Administrative Region (b) which shall not affect the general principle of this Article), exempt such Netherlands tax paid under the laws of the Netherlands and in accordance with this Agreement, whether directly or by deduction, in respect of income from tax. (b) where derived by a person who is a resident of the Kingdom Hong Kong Special Administrative Region from sources in the Netherlands, shall be allowed as a credit against Hong Kong Special Administrative Region tax payable in respect of Saudi Arabia derives items that income, provided that the credit so allowed does not exceed the amount of Hong Kong Special Administrative Region tax computed in respect of that income which, in accordance with the provisions of Articles 10, 11, 12 and paragraphs 3 and 4 of Article 13 may be taxed in the Netherlands, the Kingdom of Saudi Arabia shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Netherlands. Such deduction shall not, however, exceed that part laws of the tax, as computed before the deduction is given, which is attributable to such items of income derived from the NetherlandsHong Kong Special Administrative Region. (c) In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice to the provisions of the Zakat collection regime as regards Saudi nationals.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. The method of elimination of double taxation will be as follows: 1. In case of the The Netherlands: (a) , when the Netherlands imposes a imposing tax on its residents, it may include in the basis base upon which such taxes are imposed the items of income or capital which, according to the provisions of this Convention, may or shall be only taxable taxed in the Kingdom of Saudi ArabiaItaly. (b) However2. Where, where however, a resident of the Netherlands derives items of income or owns items of capital which according to Article 6, Article the provisions of Articles 6 and 7, paragraph 4 6 of Article 10, paragraph 5 6 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, paragraph 1 of Article 14, paragraph 1 of Article 15, paragraphs 1 (a) Articles 16 and 2 (a) of Article 19 and 19, paragraph 2 of Article 22 and paragraphs 1 and 2 of Article 23 of this Convention may be taxed in the Kingdom of Saudi Arabia Italy and are included in the basis base referred to in paragraph 1 (a)1, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of the Netherlands law for the avoidance of double taxation, which may be subject to modifications without affecting the general principle thereof. For that purpose the said items of income shall be deemed to be included in the total amount of the items of income or capital which are exempt from Netherlands tax under those provisions. (c) 3. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 (b) of Article 10, paragraph 3 of Article 13, Article 16, paragraphs 1 and 2 of Article 17 and 11, paragraph 3 2 of Article 18 12, and Article 17 of this Convention may be taxed in the Kingdom of Saudi Arabia Italy to the extent that these items are included in the basis base referred to in paragraph 1 (a)1. The amount of this deduction shall be equal to the tax paid in the Kingdom of Saudi Arabia Italy on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provide so, shall not exceed the amount of the deduction reduction which would be allowed if the items of income so included in the taxable base were the sole items of income which are were exempt from Netherlands tax under the provisions of the Netherlands law for the avoidance of double taxation. This paragraph shall not restrict allowance now or hereafter accorded by the provisions of the Netherlands law for the avoidance of double taxation, but only as far as the calculation of the amount of the deduction of Netherlands tax is concerned with respect to the aggregation of income from more than one country and the carry forward of the tax paid in the Kingdom of Saudi Arabia on the said items of income to subsequent years. (d) Notwithstanding the provisions 4. Where a resident of paragraph 1 (b) of this Article, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in the Kingdom of Saudi Arabia on Italy derives items of income which according to Article 7, paragraph 4 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12 and paragraph 2 of Article 22 of this Convention may be taxed in the Kingdom of Saudi Arabia to the extent that these items are included in the basis referred to in paragraph 1 (a), insofar as the Netherlands under the provisions of the Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 1 (c) of this Article shall apply accordingly. 2. In case of the Kingdom of Saudi Arabia: (a) where a resident of the Kingdom of Saudi Arabia derives income which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, Italy may, when imposing tax on income as referred to in Article 2 of this Convention, include these items of income in the Kingdom of Saudi Arabia shalltaxable base upon which aforementioned taxes are imposed, subject to the unless specific provisions of this Convention provide otherwise. In that case Italy shall deduct from the taxes so calculated the income tax paid in the Netherlands, but the amount of such deduction may not exceed that part of the Italian tax which is attributable to that income in the ratio that such income bears to total income. Nevertheless, no deduction shall be granted if the item of income is subjected in Italy, according to Italian law and upon request of the recipient, to taxation by way of withholding at source. In determining the amount of the Netherlands tax, no account shall be taken of the investment premiums and bonuses and disinvestment payments as provided for by the Netherlands Investment Account Law (Wet investeringsrekening). 5. Where gains or income which may be taxed in one of the States by virtue of paragraph 5 of Article 13 or paragraph 2 (b) of this ArticleArticle 18, exempt such income from tax. (b) where respectively, is derived by a resident of the Kingdom of Saudi Arabia derives items of income which, in accordance with the provisions of Articles 10, 11, 12 and paragraphs 3 and 4 of Article 13 may be taxed in the Netherlandsother State, the Kingdom of Saudi Arabia first-mentioned State shall allow as a deduction from the its tax on the such gains or income of that resident an amount equal to the tax paid levied on those gains or that income in the Netherlandsother State. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is givendeduction, which is attributable to such items of the gains or income derived from that may be taxed in the Netherlandsfirst-mentioned State. (c) In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice to the provisions of the Zakat collection regime as regards Saudi nationals.