ARTICLE 23
U.S. Income Tax Treaty — Netherlands - Income Tax Treaty (1992) · 2026-10-03 edition · updated 2026-10-04 · United States
Other Income
Items of income of a resident of one of the States, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
The provisions of paragraph 1 shall not apply to income, other than income from real property as defined in paragraph 2 of Article 6 (Income from Real Property), if the beneficial owner of the income, being a resident of one of the States, carries on business in the other State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the income is attributable to such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 15 (Independent Personal Services), as the case may be, shall apply.
CHAPTER IV ELIMINATION OF DOUBLE TAXATION
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