The ECJ X Case (Football Club Feyenoord)

Withholding taxes on fees paid to non-resident sportsmen and artistes have long represented an obstacle to the cross-border provision of services within the European Union, as well as in the international context. Art. 17 of tax treaties based on the OECD Model is outdated and results in a significant administrative burden for taxpayers. The authors, in this article, examine the X case (Football Club Feyenoord), which highlights these issues, as well as their wider implications.