The new protocol to the Netherlands-United States tax treaty

Journal
Weijden, M. van der; Doets, M.
Bulletin for International Taxation 2004 (Volume 58), No. 7
PriceUSD 45

On 8 March 2004, the Netherlands and the US signed a protocol to the 1992 Netherlands-USA income tax treaty. This article first compares the direct and indirect stock exchange tests and the ownership/base erosion test in the LOB provision of the new treaty with the corresponding provisions of the current treaty and then discusses the new derivative benefits clause. It also considers the new dividend article.