Dutch tax treaty analysis

A tax treaty determines which state is allowed to levy taxes on a specific item of income. The Netherlands has over 90 different tax treaties. In some cases the meaning of phrases or words used in tax treaties can be ambiguous or confusing. This might lead to uncertainty as to which state is allowed to levy taxes. In case a state is allowed to levy taxes then the tax treaty might limit the amount of taxation levied.

Tax treaty analysis helps to clarify uncertainties and mitigate risks. We have performed various tax treaty analysis, with a focus on the application of the limitation on benefits article in the Netherlands-US tax treaty and the application of the  hybride entity clause in the Netherlands-US tax treaty.

What does Dutch tax treaty analysis cover?

Typically tax treaty analysis covers various interpretation methods such as:

  • grammatical interpretation of Dutch tax treaties
  • historical interpretation of Dutch tax treaties
  • systematic interpretation of Dutch tax treaties
  • teleological interpretation of Dutch tax treaties

In the Netherlands the grammatical interpretation method is often used as the primary interpretation method for tax treaty analysis. As guidance often the OECD Model Convention, with respect to Taxes on Income and on Capital, as well as the commentary thereto, typically provide a good start. With our considerable experience dealing with tax treaties we can clarify uncertainties and mitigate risks.

More information on Dutch tax treaty analysis

For more information on Dutch tax treaties, please refer to our Dutch tax treaty overview. If you would like more information, please do not hesitate to contact us.

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