Ad Article. 24 In the case of the Kingdom of Saudi Arabia, the methods for elimination of double taxation will not prejudice the provisions of the Zakat collection regime as regards the Saudi nationals. IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol. DONE in Beijing on the 23rd day of January, 2006 in duplicate, each in the Chinese, Arabic and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. For the Government of For the Government of The People’s Republic of China The Kingdom of Saudi Arabia Xx. Xxx Xuren Xx. Xxxxxxx Bin Xxxxxxxxx Xx-Xxxxx Commissioner Minister of Finance of the State Administration of Taxation
Ad Article. 2 The Contracting Parties shall within the framework of their national legislation give sympathetic consideration to applications for the entry and sojourn of persons of either Contracting Party who wish to enter the territory of the other Contracting Party in connection with an investment; the same shall apply to employed persons of either Contracting Party who in connection with an investment wish to enter the territory of the other Contracting Party and sojourn there to take up employment. Applications for work permits shall also be given sympathetic consideration.
Ad Article. 5 For the purposes of subparagraphs (f) and (g) of paragraph 4 it is understood that the mere facilitation of the conclusion (including the mere signing) of contracts concerning loans, concerning the delivery of goods or merchandise or concerning technical services shall be considered as an activity of a preparatory or auxiliary character.
Ad Article. 4 An individual living aboard a ship without any real domicile in either of the Contracting States shall be deemed to be a resident of the Contracting State in which the ship has its home harbour.
Ad Article. 4 In the case of an individual, he will only be considered as a resident for the purposes of the Convention when such individual:
Ad Article. 12 If in the event that, after the signing of this Convention, the Czech Republic signs with a third State an Agreement which limits the taxation of royalties arising in the Czech Republic to a rate lower, including exemption, than the rate provided for in subparagraph a) or b) of paragraph 2 of Article 12 of the Convention, as the case may be, that lower rate or exemption will automatically be applicable for the purposes of this Convention from the date of which the Agreement between the Czech Republic and that third State will have effect.
Ad Article. 16 It is understood that „bestuurder‟ or „commissaris‟ of a Netherlands company means persons, who are nominated as such by the general meeting of shareholders or by any other competent body of such company and are charged with the general management of the company and the supervision thereof, respectively.
Ad Article. 23 It is understood that for the computation of the reduction mentioned in paragraph 2 of Article 23, the items of capital referred to in paragraph 1 of Article 22 shall be taken into account for the value thereof reduced by the value of the debts secured by mortgage on the capital and the items of capital referred to in paragraph 2 of Article 22 shall be taken into account for the value thereof reduced by the value of the debts pertaining to the permanent establishment or fixed base. IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol. DONE at New Delhi this thirtieth day of July, 1988, in duplicate, in the Hindi, Netherlands and English languages, the three texts being equally authentic. In case of divergence between the Netherlands and Hindi texts, the English text shall be the operative one.
Ad Article. 2 It is understood that the Convention shall not apply to taxes withheld at source on income by chance covered by Article 6 of the Swiss Anticipatory Tax Law.
Ad Article. 22 The exemption provided in sub-paragraph (b) of paragraph 1 of Article 22 shall not apply if it was the main purpose of any person concerned with the creation or assignment of the shares or other rights in respect of which the income is paid to take advantage of this provision by means of that creation or assignment. In that case, subparagraphs 10.2.a) ii) or 10.4 a) ii) shall apply. The provisions of sub-paragraph (d) of paragraph 1 of Article 22 shall cease to have effect after 10 years since the entry into force of this Agreement. After this period, the Competent Authorities will jointly consider an extension of the provisions hereinbefore mentioned.
