A tax under the name ‘Winstbelasting’ (Profit Taxation) shall be levied on: a The profits of corporations, limited partnerships, joint stock companies, companies or associations, the capitalization of which is divided, totally or partially into shares, co-operative societies and mutual insurance societies, having their statutory seat within the Netherlands Antilles. b The profits of associations having their statutory seat within the Netherlands Antilles, the capitalization of which is not divided into shares, and of foundations engaged in trade or business other than those which exclusively serve the general public interest. c The profits of entities having this statutory seat without the Netherlands Antilles (including corporations, partnerships or associations, the capitalization of which is divided, totally or partially into shares) gained from trade or business conducted through a permanent establishment within the Netherlands Antilles, or from immovable properties situated within the Netherlands Antilles, as well as gains from receivables not in the ordinary course of business of the company, in so far as the principal is secured by mortgage upon said immovables.