Interest or dividend? – Netherlands-Brazil DTA Facts: The appellant, a Netherlands-based company, holds 99.9% interest in a Brazilian …
Interest or dividend? – Netherlands-Brazil DTA Facts: The appellant, a Netherlands-based company, holds 99.9% interest in a Brazilian …
Pension taxability – Netherlands-Belgium DTA Facts: In 2019, the appellant was a tax resident in Belgium and received …
Fixed place PE – Germany-UK DTA Facts: The appellants were tax residents of Germany and formed a general …
Dependent personal services” article of Germany-France DTA Facts: The appellants are a married couple who were jointly taxed …
