Intra-Firm Transactions – What if Member States Subjected Taxpayers to Unlimited Income Taxation whilst Granting Double Tax Relief under a Netherlands-Style Tax Exemption?

In this article, the author examines, through examples, the effects of Member States subjecting taxpayers to unlimited income taxation whilst granting double tax relief under a Netherlands-style tax exemption from the perspective of how such an approach would affect the cross-border taxation of intra-firm transactions.