Treedt in werking op een nader te bepalen tijdstip
- 1
- Notwithstanding the provisions of paragraphs 1, 2, and 9 of Article 10, dividends paid by a company which under the laws of the Netherlands is a resident of that State, to an individual who is a resident of Malawi and who upon ceasing to be a resident of the Netherlands is taxed on the appreciation of capital as meant in paragraph 2 of this provision, may also be taxed in the Netherlands in accordance with the laws of the Netherlands, but only insofar as the assessment on the appreciation of capital is still outstanding.
- 2
- Where an individual has been a resident of the Netherlands and has become a resident of Malawi, paragraph 5 of Article 13, shall not prevent the Netherlands from taxing under its domestic law the capital appreciation of shares, profit sharing certificates, call options and usufruct on shares and profit sharing certificates, in and debt-claims on a company for the period of residency of that individual in the Netherlands. In such case, the appreciation of capital taxed in the Netherlands shall not be included in the tax base when determining the appreciation of capital by Malawi.
