- 1
- The Netherlands shall not be prevented from taxing income with respect to an interest in a tax exempt investment institution (“vrijgestelde beleggingsinstelling”) according to its domestic law, but if the beneficial owner of such income is a resident of Andorra, the tax so charged shall not exceed 15 per cent of the gross amount of the income.
- 2
- The provisions of paragraph 3 of Article 10 shall not apply to dividends paid by or received by a person that is a collective investment vehicle.
- 3
- It is understood that a person that for the purposes of the company tax of the Netherlands is a fiscal investment institution (“fiscale beleggingsinstelling”) is considered to be a collective investment vehicle.
