The Dutch Approach to the Attribution of Profits to Permanent Establishments

Journal
Sahin, L.G.C.; Blanc, B. le
Netherlands
European Taxation 2011 (Volume 51), No. 6
FormatPDF
EUR
40
| USD
45
(VAT excl.)

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.