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 State received interest from third States in the context of which the underlying indebtedness was ...

INTERNATIONAL - ARTICLE 15(2)(B) OF THE OECD MODEL: PROBLEMS ARISING FROM THE RESIDENCE REQUIREMENT FOR CERTAIN TYPES OF EMPLOYERS - The author analyses on a case-by-case basis 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 transparent partnership or a dual resident company.

Pötgens, Frank P.G., (2002)

ARTICLES - INTERNATIONAL: - THE "CLOSED SYSTEM" OF THE PROVISIONS ON INCOME FROM EMPLOYMENT IN THE OECD MODEL - In this article the author discusses the closed system represented by Article 15 et seq. of the OECD Model and the interrelationship of the tax treaty provisions covering income from employment.

Pötgens, Frank P.G., (2001)

ARTICLES - NETHERLANDS: - INTERNATIONAL ASPECTS OF THE 2001 INCOME TAX ACT - This article deals with the international tax implications of the Netherlands Income Tax Act 2001, which entered into force on 1 January 2000. The legislative process took place in what was a remarkably tight time frame for such a huge change. The authors discuss the numerous international tax law and EC law issues in the ...

Pötgens, Frank P.G., (2001)