- 1.A company which is a resident of the Netherlands and which is treated as a tax exempt investment institution (“vrijgestelde beleggingsinstelling”) for the purposes of the Netherlands company tax shall not be entitled to the benefits of Articles 10, 11, 12, 13 and 21 and the corresponding Articles of the Protocol to the Convention.
- 2.It is understood that paragraph 3, subparagraph a) of Article 10 shall not apply to a person who is a resident of the Netherlands and who is treated as a collective investment institution (“fiscale beleggingsinstelling”) for the purposes of the Netherlands company tax.
- 3.Notwithstanding the provisions of paragraphs 1 and 2 and the provisions of Article 1 and Article 4, the competent authorities of the Contracting States shall by mutual agreement decide to which extent any other resident of a Contracting State that is subject to a special regime shall not be entitled to the benefits of this Convention.