The Dutch Supreme Court Reaffirms and Clarifies 'de facto employer' under Art. 15 of the OECD Model

this article discusses six decisions of the Dutch Supreme Court of 1 December 2006, BNB 2007/75-79 and V-N 2006/65.9. In these decisions the Supreme Court confirmed that the expression 'employer' be given a substantive meaning and , further, clarified the scope of this meaning for purposes of Dutch tax treaties patterned on Art. 15 of the OECD Model.