Artikel 22 Verdrag tussen het Koninkrijk der Nederlanden, ten behoeve van Curaçao, en de Republiek Suriname tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen en naar het vermogen en het voorkomen van het ontduiken en ontwijken van belasting

Article 22 Elimination of double taxation 1 Curaçao may include in the basis upon which taxes are imposed on its residents, the items of income which according to the provisions of this Convention may be taxed in the other Contracting State. In such cases, however, Curaçao shall allow a deduction from Curaçao tax according to the provisions of paragraphs 2, 3 and 4, except to the extent that the provisions of this Convention allow taxation by the other Contracting State solely because the items of income are also income derived by a resident of the other Contracting State. 2 Where a resident of Curaçao derives items of income which according to paragraph 1 of Article 6, paragraph 1 of Article 7, paragraphs 1, 2, 4 and 6 of Article 13, paragraphs 1 and 3 of Article 14, paragraphs 2 and 5 of Article 17, paragraph 1 (subparagraph a) of Article 18, Article 19 and paragraph 2 of Article 20 of this Convention may be taxed in the other Contracting State and are included in the basis referred to in paragraph 1, Curaçao shall exempt such items of income by allowing a deduction from the Curaçao tax. This deduction is calculated based on the exemption with progression method taking into account the provisions of laws of Curaçao for the avoidance of double taxation where applicable. 3 The provisions of paragraph 2 shall not apply to items of income derived by a resident of Curaçao where the other Contracting State applies the provisions of this Convention to exempt such items of income from tax or applies the provisions of paragraph 2 of Article 10 to such items of income. In such case, the provisions of paragraph 4 shall apply accordingly. 4 Further, Curaçao shall allow a deduction from Curaçao tax so computed for the items of income which according to paragraphs 2, 3 and 9 of Article 10, paragraph 1 of Article 15, paragraph 1 of Article 16, Article 17 and paragraphs 1 and 2 of Article 21 of this Convention may be taxed in the other Contracting State to the extent that these items are included in the basis referred to in paragraph 1. This deduction shall be computed in conformity with the provisions of the laws of Curaçao for the elimination of double taxation. 5 Where a resident of a Contracting State owns capital which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall exempt such capital from tax. The first-mentioned State may nevertheless, in calculating the amount of tax on the remaining capital of such resident, take into account the exempted capital. 6 In Suriname, double taxation shall be eliminated as follows: a) where a resident of Suriname derives items of income which, in accordance with the provisions of this Convention, may be taxed in Curaçao, Suriname shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Curaçao; b) the deduction allowed under a) shall not exceed that part of the Suriname income tax, as computed before the deduction is given, which is attributable to such items of income that may be taxed in Curaçao; c) where in accordance with any provision of the Convention income derived by a resident of Suriname is exempt from tax in Suriname, Suriname may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 7 For the purpose of this article, tax that has been exempted or reduced pursuant to the statutory provisions to promote investment in one of the Contracting States shall be deemed to have been paid.