5. A person resident in a Contracting State who carries on offshore activities consisting of professional services or other activities of an independent nature in the other Contracting State shall be deemed to be engaged in that other Contracting State from a fixed base. However, this paragraph shall not apply where such activities are carried on in the other Contracting State during one or more periods not exceeding a total of 30 days in a twelve-month period. If you are sent abroad for a short-term assignment (up to 2 years), you will remain in the social security system of your home country. However, income earned during an assignment abroad may be taxed in the host country. Unless this paragraph applies where the beneficial owner of the dividend ceases that the shares were acquired in good faith for commercial reasons and not primarily to secure the benefit of this Article. The abusive practice is that a person receives benefits from an agreement without being the legitimate beneficiary, for example when. B a company established in a State where an agreement granting special tax treatment for foreign income is in force transfers its profits to another entity (beneficial owner) located in another State. If you work in another EU country – outside the EU country where you are a tax resident – as an artist (. B musician, theater, film, radio or television) or as a sports professional, the income you receive can be taxed in the country where the money was earned.
This may also be the case if you are paid indirectly through another person or .B another company (for example, a management company, a team, a troupe or an orchestra). 2. This Convention shall enter into force thirty days after the date of exchange of the instruments of ratification and shall take effect thereafter: 2. This Convention shall also apply to all identical or substantially similar taxes levied in addition by one of the States Parties after the date of signature of this Convention, or in lieu of the taxes of that Contracting State referred to in paragraph 1 of this Article. The competent authorities of the Contracting States shall inform each other of any substantial change in their respective tax laws. If you live in an EU country but earn all or almost all of your income in another country and pay taxes there, the country where you earn your income should treat you as it would treat a resident, i.e. it should grant you the same tax breaks and exemptions and any other tax benefits available to residents. such as personal deductions or the ability to file a joint tax return with your spouse. (c)if he has his habitual residence in both or in either Contracting State, he shall be deemed to reside in the Contracting State of which he is a national; 4. A person acting in a Contracting State on behalf of an enterprise of the other Contracting State, with the exception of an independent representative to whom paragraph 5 of this Article applies, shall be deemed to be a permanent establishment in the first-mentioned State if he has the power in that State to conclude contracts on behalf of the enterprise and ordinarily carries on it in that State, unless: its activity is limited to the purchase of goods or merchandise for the company. In general, interest (Article 11) may be taxed in the country where it originates, but the rate is limited to 10 per cent if the beneficial owner of the interest resides in the other country. For different categories of interest (e.B.
if the interest is paid by the government of the country of origin), the country of origin is exempt from the tax paid to a resident of the other country. 3.