Artikel 24 Overeenkomst tussen de Regering van het Koninkrijk der Nederlanden en de Regering van de Republiek Singapore 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

Article 24 Elimination of double taxation 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 Singapore. 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 paragraph 1 of this Article and may be taxed in Singapore according to Articles 6, 7, 10 (paragraph 6), 11 (paragraph 5), 12 (paragraph 4), 14 (paragraphs 1, 2 and 5), 15 (paragraph 1), 16 (paragraph 1), 17, 19 (paragraph 1) and 22 (paragraphs 1 and 2) of this Convention bears to the total income or capital which forms the basis mentioned in paragraph 1 of this Article. 3 Furthermore the Netherlands shall allow a deduction from Netherlands tax computed in accordance with the preceding paragraphs of this Article with respect to the items of income which according to Articles 11 (paragraph 2) and 14 (paragraph 6) of this Convention may be taxed in Singapore and are included in the basis mentioned in paragraph 1 of this Article. The amount of this deduction shall be equal to the tax paid in Singapore on these items of income, but shall not exceed the amount of the Netherlands tax which bears the same relation to the amount of tax computed in conformity with paragraph 1 of this Article, as the amount of the items of income mentioned in this paragraph bears to the amount of income which forms the basis mentioned in paragraph 1. 4 Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore (which shall not affect the general principle hereof) - (a) Netherlands tax payable under the laws of the Netherlands and in accordance with this Convention, whether directly of by deduction in respect of income from sources within the Netherlands, shall be allowed as a credit against Singapore tax payable in respect of that income. (b) In the case of a dividend paid by a company which is a resident of the Netherlands to a company which is a resident of Singapore and which owns directly or indirectly at least 25 per cent of the share capital in the first-mentioned company the credit shall take into account (in addition to any Netherlands tax on dividends) the Netherlands company tax payable in respect of its profits by the company paying the dividends. 5 For the purposes of paragraph 4 of this Article, income and gains derived by a resident of Singapore which may be taxed in the Netherlands in accordance with this Convention shall be deemed to arise from sources in the Netherlands.