The Relationship between Preservative Tax Assessments and Netherlands Tax Treaties: Not Always Pacta Sunt Servanda?

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Abstract

This article analyses the decisions of the Dutch Supreme Court of 20 February 2009, BNB 2009/260 through 262 and 19 June, 2009, BNB 2009/263 through 266 on the relationship between the domestic concept of preservative tax assessments and previously concluded tax treaties. The author argies that some findings of the Court concerning exit taxes on substantial shareholdings are debatable.
Original languageEnglish
Pages (from-to)183-191
Number of pages9
JournalEuropean Taxation
Volumemei
Issue numbernr. 5
Publication statusPublished - 2010

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