Supreme Court Issues Third Ruling on Fictitious Wage and Tax Treaties: Decision of the Netherlands Supreme Court of 18 November 2016, BNB 2017/34

F.P.G. Potgens; Mees Vergouwen

doi:10.59403/k55wx

Supreme Court Issues Third Ruling on Fictitious Wage and Tax Treaties: Decision of the Netherlands Supreme Court of 18 November 2016, BNB 2017/34

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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
Pages (from-to)	361-366
Number of pages	6
Journal	European Taxation
Volume	57
Issue number	8
Early online date	17 Jul 2017
DOIs	https://doi.org/10.59403/k55wx
Publication status	Published - Aug 2017

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title = "Supreme Court Issues Third Ruling on Fictitious Wage and Tax Treaties: Decision of the Netherlands Supreme Court of 18 November 2016, BNB 2017/34",

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.",

author = "F.P.G. Potgens and Mees Vergouwen",

year = "2017",

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AB - 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.

U2 - 10.59403/k55wx

DO - 10.59403/k55wx

M3 - Article

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JO - European Taxation

JF - European Taxation

IS - 8

ER -

Supreme Court Issues Third Ruling on Fictitious Wage and Tax Treaties: Decision of the Netherlands Supreme Court of 18 November 2016, BNB 2017/34

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