Artikel 12 Verdrag tussen het Koninkrijk der Nederlanden en de Syrische Arabische Republiek voor geregelde luchtdiensten

Article 12 Double Taxation 1 Income and profits from the operation of aircraft in international traffic shall be taxable only in the State in which the place of effective management of the enterprise is situated. 2 Gains from the alienation of aircraft operated in international traffic shall be taxable only in the State in which the place of effective management of the enterprise is situated. 3 Capital represented by aircraft operated in international traffic and by moveable property pertaining to the operation of such aircraft shall be taxable only in the State in which the place of effective management of the enterprise is situated. 4 The provisions of paragraph 1 of this Article shall also apply to income and profits from the participation in a pool, a joint business, a cooperative marketing arrangement or an international operating agency. 5 If an agreement between the Contracting Parties on avoidance of double taxation and the prevention of fiscal evasion on income and on capital envisages procedures different from those referred to in paragraph 1–4 of this Article, the provisions of that agreement shall be applicable.