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The new Dutch sandwich: The issue of treaty abuse

Kahale, George

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.

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More About This Work

Academic Units
Vale Columbia Center on Sustainable International Investment
Publisher
Vale Columbia Center on Sustainable International Investment
Series
Columbia FDI Perspectives, 48
Published Here
October 11, 2011
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