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ARTICLES
European Union/Netherlands
Scorpio and the Netherlands: Major Changes in Artiste and Sportsman Taxation in the European Union
Dr Dick Molenaar and Dr Harald Grams
pp. 63-68
In this article, the authors first discuss the special taxing rules for artistes and sportsmen and their effects. They then proceed to consider the implications of the European Court of Justice's judgment in the Scorpio case. Finally, the authors discuss the reasons behind the decision of the Netherlands to end the taxation of non-resident artistes and sportsmen.
Recommended reading:
Taxation of International Performing Artistes
European Union
Inaugural Lecture by Prof. Dr D.M. Weber: In Search of a (New) Equilibrium between Tax Sovereignty and the Freedom of Movement in the EC
Gerard Blokland
pp. 69-72
The author reports on the inaugural lecture of Prof. Weber, Professor of European Corporate Taxation at the University of Amsterdam. Prof. Weber first provides a preliminary survey of the subject and then considers the tax sovereignty of the Member States as a starting principle before dealing with three inherent consequences of this principle, i.e. different taxation systems and disparities, the freedom to limit tax jurisdiction and the fact that the Member States are independent.
Portugal
The International Business Centre of Madeira: Profile, Tax Incentives and Perspectives
Rui Nascimento
pp. 74-81
This article deals with the International Business Centre of Madeira (Centro Internacional de Negócios da Madeira, IBCM) that can, broadly, be defined as a preferential tax regime on Portuguese territory. In this respect the author deals with the various zones in the IBCM, the tax incentives available and, finally, considers, critically, the current IBCM and its future.
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Netherlands Antilles
Proposed and Enacted Amendments to Netherlands Antilles Tax Law
Wendela M.M. van den Brink-Van Agtmaal
pp. 82-89
In this article, the author considers various changes to the tax regime of the Netherlands Antilles that have been implemented and are intended to be implemented in the future in response to EU and OECD developments. Specifically, details are provided of the changes that, at the time of writing, had yet to be enacted and of developments regarding the Netherlands Antilles and tax treaties.
EC UPDATE
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Denmark
Triangular Cases: Art. 15 of the OECD Model, Income from Employment and the Definition of Terms
Bente Møll Pedersen
pp. 90-92
This note considers a recent Danish tax case that involved the interpretation of Art. 15 of the OECD Model Convention regarding employees' remuneration and the definition of the term "permanent establishment". In this respect, the author specifically comments on tax treaties and the interpretation of treaties with regard to the Vienna Convention on the Law of Treaties of 23 May 1969.
European Union
Vienna Conference on "The EU and Third States: Direct Taxation"
Rita Szudoczky
pp. 93-98
The conference on "The EU and Third States: Direct Taxation" organized by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration in cooperation with the European Commission and the City of Vienna was held in Vienna on 13 and 14 October 2006.
Norway
Budget for 2007 – Increased Taxation Increases Budget Surplus
Thor Leegaard
pp. 99-102
The author provides details of the Budget for 2007. Specifically, the overall effects of the Budget are considered and particulars are given relating to the changes in respect of pensions and the net wealth tax, the exit tax amendments and certain other changes, as well as (unfulfilled) rumours regarding potential changes to the exemptions for dividends and capital gains on shares.
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