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Article 13 (Royalties) of the Convention shall be amended by adding the following…

U.S. Income Tax Treaty — Netherlands - Income Tax Treaty (1992) · 2026-10-03 edition · updated 2026-10-04 · United States

"6. Notwithstanding the provisions of paragraph 1, royalties arising in one of the States and beneficially owned by an enterprise of the other State and attributable to a permanent establishment of that enterprise in a third jurisdiction, may also be taxed in the first-mentioned State if the profits of that permanent establishment are subject to an aggregate rate of tax, in the other State and the third jurisdiction in which the permanent establishment is situated, that is, in the case of royalties arising in the first-mentioned State and beneficially owned by an enterprise of the other State before January 1, 1998, less than 50 percent of the general rate of company tax applicable in the other State, and in the case of. royalties arising in the first-mentioned State and beneficially owned by an enterprise of the other State

on or after January 1, 1998, less than 60 percent of the general rate of company tax applicable in the other State, but the tax so charged shall not exceed 15 percent of the gross amount of such royalties.

However, the provisions of this paragraph shall not apply if the royalties are received as a compensation for the use of, or the right to use, intangible property produced or developed by the permanent establishment itself."

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▸Contents — U.S. Income Tax Treaty — Netherlands - Income Tax Treaty (1992)
U.S. Income Tax Treaty — Netherlands - Income Tax Treaty (1992)

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