On March 10, 2017 The Netherlands and Ghana concluded a Protocol amending the Convention between the Kingdom of the Netherlands and the Republic of Ghana for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains as concluded on March 10, 2008 (Herafter: the Protocol). On May 16, 2017 the text of the Protocol has been published on the website of the Tractatenblad.

Although the Protocol has been signed, it has not entered into force yet. For the Protocol to enter into force, the respective ratification procedures have to have been finalized in both countries.

Below we will discuss a selection of provisions included in the Protocol of which we think they might interest our readers.

Anti-abuse

The Protocol arranges that a new Article 24A “Entitlement to benefits” will be inserted in the DTA. This article contains a.o. a Principal Purpose Test.

Exchange of information

The Protocol arranges that amendments are made to Article 27 (“Exchange of information”).

Assistance in the collection of taxes

The existing DTA contains an Article regarding the assistance in the collection of taxes (Article 28). This existing article consists out 1 paragraph. The Protocol arranges that the existing Article 28 is deleted and replaced a new Article 28 containing regulations regarding the collection of taxes. The new Article 28 contains 8 paragraphs.

Click here to be forwarded to the text of the Protocol as published on the website of the Tractatenblad of May 16, 2017.

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