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Netherlands
In the aftermath of the global economic crisis, economic growth in the Netherlands began to pick up in 2014, with gross domestic product (GDP) recently exceeding its pre-crisis peak. However, as inExpand
Tax Treaty Classification of Netherlands-Source Income from Lucrative Interests ( Carried Interest )
This article discusses the tax treaty classification of Netherlands-source carried interest (income from lucrative interests) earned by nonresident taxpayers. The Netherlands legislator has created aExpand
Tax treaty compartimentalization
Netherlands: Supreme Court clarifies meaning of "director" in tax treaties
The author analyses a Netherlands Supreme Court decision of 22 December 1999, BNB 2000/94, in which the Court adopts a formal approach to defining "director" in the Wages withholding tax act. ThisExpand
Netherlands. The Netherlands Supreme Court again excludes credit of withholding tax in a triangular case
On 11 May 2007, The Netherlands Supreme Court again ruled on a triangular case, i.e. a Netherlands resident BV (a limited liability company) with a permanent establishment (PE) in the other StateExpand
Dual Residence of Companies under Tax Treaties
This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. TheseExpand
International: Article 15(2)(b) of the OECD Model : problems arising from the residence requirement for certain types of employers
Analysis on a case-by-case basis of the problems that can arise with respect to Art. 15(2)(b) of the OECD Model if the employer is a tax-exempt entity, a fiscally transparant partnership or a dualExpand
International: Tax treaty issues and the cross-border taxation of employee share options
The role of tax treaties in the cross-border taxation of employee share options is examined. The article also focuses on several recent court decisions dealing with this issue.
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