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The new Dutch sandwich: The issue of treaty abuse

George Kahale

Title:
The new Dutch sandwich: The issue of treaty abuse
Author(s):
Kahale, George
Date:
Type:
Reports
Department:
Vale Columbia Center on Sustainable International Investment
Permanent URL:
Series:
Columbia FDI Perspectives
Part Number:
48
Abstract:
Years ago, international tax lawyers introduced us to the term "Dutch sandwich." The concept was to sandwich a Dutch company between an investor from country A and its investment in country B. The combination of the extensive network of Dutch tax treaties and investor-friendly domestic Dutch tax law meant that country A's investor could reduce withholding tax on dividends out of country B and perhaps eliminate capital gains tax altogether by structuring its investment through a Dutch company.
Subject(s):
Business
Finance
International law
Item views:
597
Metadata:
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