- 1
- Where a company resident in Sweden derives income attributable to a permanent establishment in the Netherlands Antilles which under the laws of the Netherlands Antilles may be taxed in the Netherlands Antilles, Sweden shall allow – subject to the provisions of the laws of Sweden concerning credit for foreign tax (as it may be amended from time to time without changing the general principle hereof) – as a deduction from the tax on such income, an amount equal to the Netherlands Antilles tax paid in respect of such income. The term “Netherlands Antilles tax paid” shall be deemed to include the Netherlands Antilles tax which would have been paid, but for any time-limited reduction or exemption of tax granted under incentive provisions contained in the Netherlands Antilles laws designed to promote economic development to the extent that such reduction or exemption is granted for income derived from activities mentioned in Article 5 and provided that the activities have been carried out in the Netherlands Antilles.
- 2
- Where a company resident in Sweden directly holds shares representing 100 per cent of the voting power in a company resident in the Netherlands Antilles, Sweden shall exempt from tax dividends distributed by the last-mentioned company to the extent that the dividends would have been exempt under Swedish law if both companies had been Swedish companies, and provided that the profits of the last-mentioned company are derived from activities listed in Article 5 and provided that the activities have been carried out in the Netherlands Antilles.
- 3
- The provisions of the second sentence of paragraph 1 and of paragraph 2 shall only apply for the first ten years during which this Agreement is effective. This period may be extended by mutual agreement between the competent authorities.
