Maltese Laws Held To Be Special Regime under Malta-Netherlands Income and Capital Tax Treaty (1977)

The author, in this article, examines a recent decision of the Netherlands Supreme Court (Hoge Raad), in which Maltese laws, due to their low tax rate of 6.25%, were held to be a special regime under the Malta-Netherlands Income and Capital Tax Treaty (1977), thereby excluding taxpayers from the application of the treaty.