- 1
- This Convention shall apply to persons who are residents of one or both of the Contracting States.
- 2
- Where entities are considered to be transparent by one of the Contracting States and are considered to be non-transparent by the other Contracting State, and this leads to double taxation or taxation not in accordance with the provisions of this Convention, the competent authorities of the Contracting States shall find solutions pursuant to Article 22 in order to avoid double taxation or taxation not in accordance with the Convention and, at the same time, to prevent that, merely as a result of the application of the Convention, income is (partly) not subject to tax.
- 3
- In relation to the Caribbean part of the Netherlands, this Convention shall apply only to resident individuals.
