- 1
- Income from an estate or a trust which is a resident of Canada accruing to a resident of the Netherlands who is the beneficiary thereof, may be taxed in the Netherlands.
- 2
- However, such income may also be taxed in Canada, and according to the laws of Canada, but the tax so charged shall not exceed 15 per cent of the gross amount of the income.
- 3
- Notwithstanding the provisions of paragraph 2, such income shall be exempt from tax in Canada to the extent of any amount paid, credited, or required to be distributed to such beneficiary out of income from sources outside Canada.
- 4
- For the purposes of this Article, a trust does not include an arrangement whereby the contributions made to the trust are deductible for the purposes of taxation in Canada.
