- a)It is understood that, in so far as the Netherlands income tax or company tax is concerned, the basis meant in the first paragraph of Article 22 is the "onzuivere inkomen or "winst" in terms of the Netherlands Income Tax Law or Company Tax Law, respectively.
- b)Notwithstanding the provisions of paragraph 4 of Article 22, as far as royalties are concerned, the percentage mentioned in that paragraph shall be increased by 5 per cent as long as the Philippine domestic legislation provides for a tax at source on royalties which is not lower than 35 per cent.
