The new Dutch sandwich: The issue of treaty abuse

George Kahale

No 48, Columbia FDI Perspectives from Columbia University, Columbia Center on Sustainable Investment (CCSI)

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.

Date: 2011
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