ARTICLE XVI (1) A resident of the Netherlands shall be exempt from United States tax upon compensation for labor or personal services performed within the United States if he is temporarily present within the United States for a period or periods not exceeding a total of one hundred eighty-three days during the taxable year and his compen- sation is received for labor or personal services performed as a worker or employee of, or under contract with, a resident of the Netherlands, or a Netherlands corporation, carrying the actual burden of the remuneration. (2) The provisions of paragraph (1) of this Article shall apply, mutatis mutandis, to a resident of the United States deriving compen- sation for labor or personal services performed within the Netherlands. Compensation for labor or personal serv- ices, tax exemption. Teachers. Students, etc. Determination of taxes. Deductions. 53 Stat. 1. 26U. S.C. ARTICLE XVII Professors or teachers, residents of one of the Contracting States, who, in accordance with agreements between the Contracting States or between teaching establishments in the Contracting States for the exchange of professors and teachers, visit the other Contracting State to teach, for a maximum period of two years, in a university, college or other teaching establishment in such other Contracting State, shall not be taxed by such other State with respect to the remuneration which they receive for such teaching. ARTCLE XVIII Students or business apprentices of one Contracting State residing in the other Contracting State exclusively for purposes of study or for acquiring business experience shall not be taxable by the latter State in respect of remittances received by them from abroad for the purpose of their maintenance or studies. ARTIcLE XIX (1) Notwithstanding any provisions of the present Convention (other than paragraph (1) of Article XV when applicable in the case of an individual who is deemed by each Contracting State to be a citizen thereof), each of the two Contracting States, in determining the taxes, including all surtaxes, of its citizens or residents or cor- porations, may include in the basis upon which such taxes are imposed all items of income taxable under its own revenue laws as though this Convention had not come into effect. (2) As far as may be in accordance with the provisions of the United States Internal Revenue Code, the United States agrees to allow as a deduction from the income taxes imposed by the United States the appropriate amount of taxes paid to the Netherlands, whether paid directly by the taxpayer or by withholding at the source. (3) As far as may be in accordance with the provisions of Nether- lands law, the Netherlands agrees to allow a deduction from Nether- 1764 TREATIES [62 STAT.
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