Notwithstanding the provisions of Articles 1 and 4, the competent authorities of the Contracting States shall, by mutual agreement, decide whether or not a resident of a Contracting State is subject to a special regime and, if so, to which extent it shall not be entitled to the benefits of this Convention. A company which is treated as a tax exempt investment institution (“vrijgestelde beleggingsinstelling”) as meant in the Netherlands Corporate Income Tax Act 1969 shall not be entitled to the benefits of Articles 10, 11, 12, 13 and 21 and the corresponding Articles of this Protocol.
