Netherlands - The Dutch Approach to the Attribution of Profits to Permanent Establishments
- L. Sahin; B. le Blanc
- European Taxation, 2011 (Volume 51), No 6
- 6 May 2011
In this article, the authors outline and comment on the Decree of the Dutch State Secretary of Finance on the attribution of profits to a permanent establishment, which was released in response to the 2010 amendments to Art. 7 of the OECD Model Tax Convention, as well as a recent announcement of the Dutch State Secretary of Finance regarding the Dutch tax treatment of foreign permanent establishments.