It is agreed that double taxation shall be avoided in the following manner:
- A.In the case of the Netherlands:
- 1.The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income or capital which, according to the provisions of this Convention, may be taxed in Greece.
- 2.However, where a resident of the Netherlands derives items of income or owns capital which according to Article 6, Article 7, paragraph 4 of Article 10, paragraph 4 of Article 11, paragraph 4 of Article 12, paragraph 1 and 2 of Article 14, Article 15, paragraph 1 of Article 16, paragraph 1 of Article 17, Article 20, paragraph 2 of Article 23 and paragraphs 1 and 2 of Article 24 of this Convention may be taxed in Greece and are included in the basis referred to in paragraph 1, the Netherlands shall exempt such items by allowing a reduction of its tax. This reduction shall be computed in conformity whith the provisions of Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the total amount of the items of income which are exempt from Netherlands tax under those provisions.
- 3.Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 (b) of Article 10, paragraph 2 of Article 11, paragraph 2 of Article 12, paragraph 5 of Article 14, paragraph 3 of Article 16, Article 18 and paragraph 2 of Article 19 of this Convention may be taxed in Greece to the extent that these items are included in the basis referred to in paragraph 1. The amount of this deduction shall be equal to the tax paid in Greece on these items of income, provided that in the case of dividends not more than 15 percent of the gross amount thereof is taken into account, but shall not exceed the amount of the reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
- B.In the case of Greece:
- 1.Greece, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income or capital which, according to the provisions of this Convention, may be taxed in the Netherlands.
- 2.Where a resident of Greece derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the Netherlands, Greece shall allow:
- (i)as a deduction from the tax on income of that resident, an amount equal to the tax on income paid in the Netherlands;
- (ii)as a deduction from the tax on capital of that resident, an amount equal to the tax paid in the Netherlands. Such deduction in either case shall not, however, exceed that part of the tax on income or on capital, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in the Netherlands.
