Annex to Advocate General's conclusion on whether or not Art. 17 of the OECD Model applies to the basic salaries of sportsmen

The author considers the Appendix to the conclusions of the Advocate General of the Netherlands Supreme Court in relation to three contradictory cases involving the question of whether or not a Netherlands resident sportsman is, in respect of his basic salary and regarding days in which sporting activities are performed outside the Netherlands, entitled to the application of treaty provisions