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The Attribution of Income in the Netherlands and the United Kingdom

J. Wheeler
World Tax Journal, 2011 (Volume 3), No 1
9 February 2011
This article undertakes an extensive comparison of the domestic law of the Netherlands and the United Kingdom in respect of the attribution of income to a person for tax purposes. After a general introduction to both countries, the article looks at a series of specific situations in which the attribution of income may be an issue. It goes on to consider the factors that play a role in that determination and the relative weight of those factors.Although the very broad principles in the two countries are similar, this study finds some basic disparities between them and a myriad of differences in the detail. More importantly, the study demonstrates that, even as between these two countries, the attribution issue is too complex to be captured in a general statement of the relevant factors. The final conclusion is that it is not useful to attempt to define a substantive attribution rule for tax treaties.
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