The Relationship between Tax Treaties and Protective Tax Assessments Issued in Respect of Pensions and Annuities upon Emigration: Pacta sunt servanda and Compartmentalization

Journal
Pötgens, F.P.G.; Kool, E.M.L.
Netherlands
European Taxation 2018 (Volume 58), No. 9
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In this note, the authors examine a recent Supreme Court decision wherein the Court held that Netherlands legislation that governs how taxpayers with a pension or annuity entitlement should be treated in the event of emigration complies with the good faith required to be observed in applying and interpreting treaties.