UK/NETHERLANDS DOUBLE TAXATION CONVENTIONAND PROTOCOLSIGNED 26 SEPTEMBER 2008Amended by Protocol signed on 12 June 2013Entered into force 25 December 2010Effective in the United Kingdom from 1 April 2011 for corporationtax and from 6 April 2011 for income tax and capital gains taxEffective in the Netherlands from 1 January 2011HM Revenue & CustomsAugust 20181

ContentsARTICLE 1 . 5Persons Covered. 5ARTICLE 2 . 5Taxes Covered . 5ARTICLE 3 . 6General Definitions . 6ARTICLE 4 . 7Residence . 7ARTICLE 5 . 8Permanent Establishment . 8ARTICLE 6 . 10Income from Immovable Property . 10ARTICLE 7 . 10Business Profits . 10ARTICLE 8 . 11Shipping and Air Transport. 11ARTICLE 9 . 11Associated Enterprises . 11ARTICLE 10 . 12Dividends . 12ARTICLE 11 . 13Interest . 13ARTICLE 12 . 14Royalties . 14ARTICLE 13 . 14Capital Gains . 14ARTICLE 14 . 16Income from Employment . 16ARTICLE 15 . 16Directors’ Fees . 16ARTICLE 16 . 17Entertainers and Sportspersons . 17ARTICLE 17 . 17Pensions . 17ARTICLE 18 . 18Government Service. 182

ARTICLE 19 . 19Students . 19ARTICLE 20 . 19Other Income . 19ARTICLE 21 . 20Elimination of Double Taxation . 20ARTICLE 22 . 22Miscellaneous Provisions . 22ARTICLE 23 . 23Offshore Activities . 23ARTICLE 24 . 24Non-Discrimination . 24ARTICLE 25 . 25Mutual Agreement Procedure . 25ARTICLE 26 . 26Exchange of Information . 26ARTICLE 27 . 27Assistance in the Collection of Taxes . 27ARTICLE 28 . 28Members of Diplomatic or Permanent Missions and Consular Posts . 28ARTICLE 29 . 28Territorial Extension . 28ARTICLE 30 . 29Entry into Force . 29ARTICLE 31 . 30Termination . 30PROTOCOL . 31I. With reference to paragraph (3) of Article 2 (Taxes covered) . 31II. With reference to paragraph (1) of Article 4 (Residence) . 31III. With reference to paragraph (1), sub-paragraph (l) of Article 3 (General definitions),paragraph 2, sub-paragraph (a) of Article 4 (Residence) paragraph 2, sub-paragraph (b) (ii) ofArticle 10 (Dividends) and paragraph (4), sub-paragraph (c) of Article 13 (Capital gains) . 31IV. With reference to paragraph (1) of Article 9 (Associated enterprises) . 31V. With reference to Articles 10 (Dividends) and 11 (Interest) . 31VI. With reference to Articles 10 (Dividends) and 13 (Capital Gains) . 32VII. With reference to Articles 11 (Interest) and 12 (Royalties) . 32VIII. With reference to Article 15 (Directors’ fees) . 323

IX. With reference to Article 17 (Pensions) . 32X. With reference to paragraph 3 of Article 17 (Pensions) . 33XI. With reference to Article 18 (Government service) . 33XII. With reference to paragraph (2) of Article 21 (Elimination of double taxation) . 33XIII. With reference to paragraph (3) of Article 30 (Entry into force) . 334

CONVENTION BETWEEN THE GOVERNMENTS OF THE UNITEDKINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THEGOVERNMENT OF THE KINGDOM OF THE NETHERLANDS FOR THEAVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCALEVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITALGAINSThe Government of the United Kingdom of Great Britain and Northern Ireland and the Governmentof the Kingdom of the Netherlands;Desiring to conclude a new Convention for the avoidance of double taxation and the prevention offiscal evasion with respect to taxes on income and on capital gains; Have agreed as follows:ARTICLE 1Persons CoveredThis Convention shall apply to persons who are residents of one or both of the Contracting States.ARTICLE 2Taxes Covered(1) This Convention shall apply to taxes on income and on capital gains imposed on behalf ofa Contracting State, irrespective of the manner in which they are levied.(2) There shall be regarded as taxes on income and on capital gains all taxes imposed on totalincome, or on elements of income, including taxes on gains from the alienation of movable orimmovable property.(3)The existing taxes to which this Convention shall apply are in particular:(a) in the Netherlands:(i)de inkomstenbelasting (income tax);(ii) de loonbelasting (wages tax);(iii) de vennootschapsbelasting (company tax) including the Government share in the netprofits of the exploitation of natural resources levied pursuant to the Mijnbouwwet(the Mining Act);(iv)de dividendbelasting (dividend tax); (hereinafter referred to as “Netherlands tax”);(b) in the United Kingdom:(i)the income tax;(ii)the corporation tax;5

(iii)the capital gains tax;(iv)the petroleum revenue tax;(v)the supplementary charge in respect of ring fence trades; (hereinafter referred toas “United Kingdom tax”).(4) This Convention shall also apply to any identical or substantially similar taxes that are imposedby either Contracting State after the date of signature of this Convention in addition to, or in placeof, the existing taxes. The competent authorities of the Contracting States shall notify each other ofany significant changes that have been made in their taxation laws.ARTICLE 3General Definitions(1) For the purposes of this Convention, unless the context otherwise requires:(a) the terms “a Contracting State” and “the other Contracting State” mean the Kingdom of theNetherlands (Netherlands) or the United Kingdom of Great Britain and Northern Ireland(United Kingdom) as the context requires;(b) the term “Netherlands” means the part of the Kingdom of the Netherlands that is situatedin Europe, including its territorial sea, and any area beyond the territorial sea within whichthe Netherlands, in accordance with international law, exercises jurisdiction or sovereignrights;(c) the term “United Kingdom” means Great Britain and Northern Ireland, including any areaoutside the territorial sea of the United Kingdom designated under its laws concerning theContinental Shelf and in accordance with international law as an area within which therights of the United Kingdom with respect to the seabed and subsoil and their naturalresources may be exercised;(d) the term “person” includes an individual, a company and