- 1.Notwithstanding paragraphs 1 and 2 of Article 10 and Article 20, the Netherlands shall not be prevented from applying its domestic tax law with respect to an interest in a tax exempt Investment Institution (“vrijgestelde beleggingsinstelling”) pursuant to the company tax of the Netherlands. However, if the beneficial owner is a resident of Cyprus, the tax so charged shall not exceed 15 per cent of the gross amount of the income so taxed.
- 2.The provisions of paragraphs 2 and 3 of Article 10 shall not affect the right of the Caribbean part of the Netherlands to impose revenue tax in accordance with its laws.
- 3.The provisions of paragraph 3 of Article 10 shall not apply to dividends paid by or to a person who is a Fiscal Investment Institution (Fiscale Beleggingsinstelling) for the purposes of the company tax of the Netherlands.