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- This Convention shall apply to taxes on income and capital gains imposed on behalf of one of the States or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
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- There shall be regarded as taxes on income and capital gains all taxes imposed on total income, on total capital gains or on elements of income or of capital gains, as well as taxes on capital appreciation.
- 3
- The existing taxes to which this Convention shall apply are in particular:
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- a)in the Netherlands:
- (i)de inkomstenbelasting (income tax);
- (ii)de loonbelasting(wagestax);
- (iii)de vennootschapsbelasting (company tax) including the Government share in the net profits of the exploitation of natural resources levied pursuant to the Mijnwet 1810 (the Mining Act of 1810) with respect to concessions issued from 1967, or pursuant to the Mijnwet Continentaal Plat 1965 (the Netherlands Continental Shelf Mining Act of 1965); and
- (iv)de dividendbelasting (dividend tax); (hereinafter referred to as "Netherlands tax");
- b)in Zimbabwe:
- (i) the income tax;
- (ii)the branch profits tax;
- (iii)the non-resident shareholders' tax;
- (iv) the non-residents' tax on interest;
- (v)the non-residents' tax on fees;
- (vi) the non-residents' tax on royalties; and
- (vii)the capital gains tax; (hereinafter referred to as "Zimbabwean tax").
- 4
- This Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the States shall, if necessary, notify each other of any substantial changes which have been made in their respective taxation laws.