The 2011 memorandum on Dutch tax treaty policy

The Netherlands has tax treaties with approximately 100 countries. It has laid down its general policy regarding tax treaties in the Fiscal Treaty Policy Memorandum (Notitie Fiscaal Verdragsbeleid, NFV, 2011). About a quarter of all tax treaties are with developing countries, which are recognised as a separate category: (…) “Dutch tax treaty policy takes into account the specific interests of developing countries by giving them the opportunity to provide for their own resources.” Furthermore, the NFV states that “The Netherlands will continue to show understanding in relation to developing countries in the coming years, (…) for example when it comes to requests for relatively higher withholding taxes.”

The central question in this study is whether the principles formulated in the NFV are being observed where developing countries are concerned. The tax treaties that have been concluded or renegotiated since 2011 –  with Indonesia, Kenya, Zambia, Malawi, Ethiopia and Ukraine – are central to this study.

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