The Attribution of Income in the Netherlands and the United Kingdom
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| Publication date | 2011 |
| Journal | World Tax Journal |
| Volume | Issue number | 3 | 1 |
| Pages (from-to) | 39-175 |
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| Abstract |
This article undertakes an extensive comparison of the domestic law of the Netherlands and the United Kingdom in respect of the attribution of income to a person for tax purposes. After a general introduction to both countries, the article looks at a series of specific situations in which the attribution of income may be an issue. It goes on to consider the factors that play a role in that determination and the relative weight of those factors.Although the very broad principles in the two countries are similar, this study finds some basic disparities between them and a myriad of differences in the detail. More importantly, the study demonstrates that, even as between these two countries, the attribution issue is too complex to be captured in a general statement of the relevant factors. The final conclusion is that it is not useful to attempt to define a substantive attribution rule for tax treaties.
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| Document type | Article |
| Language | English |
| Published at | http://online.ibfd.org/document/wtj_2011_01_nl_1 |
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