1. The new Dutch sandwich: The issue of treaty abuse
- Author:
- George Kahale, III
- Publication Date:
- 10-2011
- Content Type:
- Policy Brief
- Institution:
- Columbia Center on Sustainable Investment
- 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.
- Topic:
- Economics, International Trade and Finance, Markets, and Foreign Direct Investment
- Political Geography:
- Europe