Treaty Series Recueil des Traites - United Nations Treaty Collection ...
Treaty Series Recueil des Traites - United Nations Treaty Collection ... Treaty Series Recueil des Traites - United Nations Treaty Collection ...
Volume 2223, 1-39522 b) in respect of other taxes charged on income of any fiscal year beginning on or after the first day of January in the calendar year next following the year in which the Convention enters into force. Article 31. Termination This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving written notice of termination at least six months before the end of any calendar year. In such event, the Convention shall cease to have effect in both Contracting States : a) in respect of taxes withheld at source, on income derived on or after the first day of January in the calendar year next following the year in which the notice has been given; b) in respect of other taxes charged on income of any fiscal year beginning on or after the first day of January in the calendar year next following the year in which the notice has been given. In witness whereof, the undersigned, duly authorised thereto, have signed this Convention. Done in duplicate at Brussels this 21 st day of April 1999, in the English, Dutch, French and Latvian languages, all four texts being equally authentic. In the case of divergence of interpretation the English text shall prevail. For the Government of the Kingdom of Belgium: J.L.DEHAENE Prime Minister For the Government of the Republic of Latvia: V. Kristopans Prime Minister
Volume 2223, 1-39522 PROTOCOL At the moment of signing the Convention between the Republic of Latvia and the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provisions which shall form an integral part of the Convention. I. Ad Article 4, paragraph 3 It is understood that the second sentence of paragraph 3 shall not be interpreted as prohibiting a Contracting State to eliminate double taxation in accordance with Article 23 in respect of persons mentioned in paragraph 3 of Article 4. 2. Ad Article 6, paragraph 2 It is understood that the term "variable or fixed payments as consideration for the working of, or the right to work mineral deposits, sources and other natural resources" also includes payments relating to the production from such resources. 3. Ad Article 6, paragraph 3 and Article 13, paragraph it is understood that all income and gains from the alienation of immovable property may be taxed in the Contracting State in which the immovable property is situated. 4. Ad Article 7, paragraphs I and 2 There an enterprise of a Contracting State sells goods or merchandise or carries on business in the other Contracting State through a permanent establishment situated therein, the profits of that permanent establishment shall not be determined on the basis of the total amount received by the enterprise but only on the basis of the remuneration which is attributable to the actual activity of the permanent establishment for such sales or business. However, profits derived from the sale of goods or merchandise of the same or similar kind as those sold, or from other business activities of the same or similar nature as those effected, through that permanent establishment may be considered attributable to that permanent establishment if it is proved that the sale or activities were structured in a manner intended to avoid taxation in the State where the permanent establishment is situated. 5. Ad Article 10, paragraph 3 The term "dividends" also includes income - even paid in the form of interest - which is treated as income from shares by the laws of the State of which the paying company is a resident. 6. Ad Article 12, paragraphs 2 and 3 If in any convention for the avoidance of double taxation concluded by Latvia with a third State, being a member of the Organisation for Economic Co- operation and Development (OECD) at the date of signature of this Convention, Latvia after that date would agree to exclude any kind of rights or property from the definition contained in paragraph 3 or exempt royalties arising in Latvia from Latvian tax on royalties or to limit the rates of tax provided in paragraph 2, such definition or exemption or lower rate shall automatically apply as if it had been specified in paragraph 3 or paragraph 2 respectively. 7. Ad Article 12, paragraph 3
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Volume 2223, 1-39522<br />
b) in respect of other taxes charged on income of any fiscal year beginning on or<br />
after the first day of January in the calendar year next following the year in which the Convention<br />
enters into force.<br />
Article 31. Termination<br />
This Convention shall remain in force until terminated by a Contracting State. Either<br />
Contracting State may terminate the Convention, through diplomatic channels, by giving<br />
written notice of termination at least six months before the end of any calendar year. In<br />
such event, the Convention shall cease to have effect in both Contracting States :<br />
a) in respect of taxes withheld at source, on income derived on or after the first day<br />
of January in the calendar year next following the year in which the notice has been given;<br />
b) in respect of other taxes charged on income of any fiscal year beginning on or<br />
after the first day of January in the calendar year next following the year in which the notice<br />
has been given.<br />
In witness whereof, the undersigned, duly authorised thereto, have signed this Convention.<br />
Done in duplicate at Brussels this 21 st day of April 1999, in the English, Dutch, French<br />
and Latvian languages, all four texts being equally authentic. In the case of divergence of<br />
interpretation the English text shall prevail.<br />
For the Government of the Kingdom of Belgium:<br />
J.L.DEHAENE<br />
Prime Minister<br />
For the Government of the Republic of Latvia:<br />
V. Kristopans<br />
Prime Minister