Orbitax1970 Treaty between Netherlands and Belgium – Dutch Supreme Court decides on taxing rights with respect to a devaluated debt-claim
|Treaty Development|Belgium; Netherlands
On 1 March 2013, the Dutch Supreme Court (Hoge Raad der Nederlanden) gave its decision in X v. Tax Administration on the taxing rights with respect to a devaluated debt-claim under the Belgium - Netherlands Income and Capital Tax Treaty (1970) (the Treaty). Details of the case are summarized below.
(a) Facts. The taxpayer was a resident of Belgium. He was the sole shareholder of a Dutch BV…
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