Netherlands - Egypt Double Tax
I am Australian, and want to live/reside in the Netherlands, and work abroad in Egypt on a 28 day on, 28 day off roster.
This question relates to where I pay tax under the DTA.
In the DTA, it states;
Article 15. Dependent personal services
1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
Article 22. Elimination of double taxation
1. The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this Agreement, may be taxed in Egypt.
2. However, where a resident of the Netherlands derives items of income which according to (snip) paragraph 1 of Article 15,(snip) of this Agreement may be taxed in Egypt and are included in the basis referred to in paragraph 1, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of Netherlands law
for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the total amount of the items of income which are exempt from Netherlands tax under those provisions.
Does this mean Netherlands uses the EXEMPTION method - whereby I pay tax in Egypt, and not in Netherlands? Or the CREDIT method, where I pay tax in both places, and claim a credit on the higher amount.