The New Partnership Approach in the 2003 Belgium-Netherlands Tax Treaty

Since 1 January 2003, a new double tax Treaty is applicable between Belgium and the Netherlands. The old Treaty of 1970 already included a specific provision relating to partnerships. Including three distinct provisions has now expanded the tradition and it is the objective of this expose to examine these provisions in their domestic and international context. For that purpose, first the general approach under the previous Treaty and under the OECD Commentary will be outlined. Next the authors will place the domestic classification rules for foreign entities of each Contracting State under scr... Mehr ...