Abstract
The authors, in this note, analyse the decision of the Netherlands Supreme Court in BNB 2017/34 (18 November 2016), wherein the Court addressed the impact of the fictitious wage concept in article 12a of the Wage Withholding Tax on classification under the Netherlands-Portugal Income and Capital Tax Treaty (1999) in respect of a Portuguese resident individual shareholder having a substantial interest in a Netherlands resident company.
Original language | English |
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Pages (from-to) | 361-366 |
Number of pages | 6 |
Journal | European Taxation |
Volume | 57 |
Issue number | 8 |
Early online date | 17 Jul 2017 |
DOIs | |
Publication status | Published - Aug 2017 |