Anti-treaty shopping restrictions in the new U.S.-Netherlands tax treaty.

From: Tax Executive | Date: September 1, 1993| Author: Wacker, Raymond F. | Copyright information

The US and Netherlands have just completed negotiations for a new tax treaty that prevents treaty shopping by third-country corporations investing in the US. The treaty has few provisions that benefit the Dutch and is mainly an emendation of the old treaty to reflect US Treasury Dept anti-treaty shopping goals. The main method used to prevent treaty shopping is to limit the corporate ownership percentage held by non-Dutch residents through a series of tests. Decisions can be appealed but the ...

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