- 1
- Notwithstanding the provisions of Article 1, the competent authorities of the Contracting States may by mutual agreement decide to which extent a resident of a Contracting State that is subject to a special regime shall not be entitled to the benefits of this Convention.
- 2
- It is understood that a person, other than an individual, shall be regarded to be liable to tax:
-
- a)in the Netherlands if the person is a resident of the Netherlands for the purposes of the company tax or the revenue tax;
- b)in Ethiopia if the person is resident of Ethiopia for the purposes of the income tax;
- provided that the income derived by that person is treated under the tax laws of that State as income of that person and not as the income of the person’s beneficiaries, members or participants.
