- 1
- For so long as Vietnam continues to grant to investors licences under the Law on Foreign Investment in Vietnam, which specify the taxation to which the investor shall be subject, the imposition of such taxation shall not be regarded as breaching the terms of paragraph 2 of Article 24.
- 2
- If Vietnam after 1 July 1993 has signed an Agreement for the avoidance of double taxation with a member State of the Organisation for Economic Cooperation and Development with a provision which provides for a treatment in conformity with or comparable to that as provided for in Article 24 of the Model Tax Convention of the afore-mentioned organisation, as published in 1992, then such provision will apply to residents of both Contracting States; in that case the foregoing paragraph shall no longer apply.
- 3
- Notwithstanding the provisions of paragraph 2 of Article 24, the percentage provided for in that paragraph shall be reduced to 7 per cent of the profits remitted from the permanent establishment to the head office as long as the profits remitted are exempt from tax in the Netherlands under subparagraph (b) of paragraph 2 of Article 23 of the Agreement.
- 4
- If Vietnam after 1 July 1993 has signed an Agreement for the avoidance of double taxation with a member State of the Organisation for Economic Cooperation and Development which provides for a lower rate on profits remitted from the permanent establishment to the head office (including a zero rate) then this lower rate will apply to residents of the Netherlands.
