Artikel 22 Verdrag tussen de Regering van het Koninkrijk der Nederlanden en de Regering van de Arabische Republiek Egypte tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen

Article 22 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 which, according to the provisions of this Agreement, may be taxed in Egypt. 2 However, where a resident of the Netherlands derives items of income which according to Article 6, Article 7, paragraph 8 of Article 10, paragraph 6 of Article 11, paragraph 5 of Article 12, paragraphs 1 and 2 of Article 13, Article 14, paragraph 1 of Article 15, paragraph 3 of Article 18, paragraphs 1 (subparagraph a) and 2 of Article 19 and paragraph 2 of Article 21 of this Agreement may be taxed in Egypt and are included in the basis referred to in paragraph 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 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. 3 Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 of Article 10, paragraph 2 of Article 11, paragraph 2 of Article 12, paragraph 5 of Article 13, Article 16, Article 17 and paragraph 1 and 2 of Article 18 of this Agreement may be taxed in Egypt to the extent that these items are included in the basis referred to in paragraph 1. The amount of this deduction shall be equal to the tax paid in Egypt on these items of income, but shall not exceed the amount of the 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 Netherlands law for the avoidance of double taxation. 4 Notwithstanding the provisions of paragraph 2, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in Egypt on items of income which according to Article 7, paragraph 8 of Article 10, paragraph 6 of Article 11, paragraph 5 of Article 12, Article 14 and paragraph 2 of Article 21 of this Agreement may be taxed in Egypt to the extent that these items are included in the basis referred to in paragraph 1, if and insofar as the Netherlands under the provisions of 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 3 of this Article shall apply accordingly. 5 In the case of Egypt, where income in accordance with the provisions of this Agreement is subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following. Netherlands tax payable in respect of income derived from the Netherlands shall be allowed as a credit against Egyptian tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of the Netherlands to a company which is a resident of Egypt and which owns directly or indirectly not less than 10 per cent of the share capital of the first-mentioned company, the credit shall take into account the Netherlands tax payable by that company on the portion of its profits out of which the dividend is paid. The credit shall not, however, exceed that part of the Egyptian tax, as computed before the credit is given which is appropriate to such items of income.