OrbitaxAG: Most-favoured nation treatment and Community preference do not require extension of the tax sparing credit under tax treaties with Brazil and Greece to third countries
|Treaty Development|Netherlands-Belgium-Brazil-Greece-Spain
On 5 June 2007, the Advocate General (AG Wattel) of the Netherlands Supreme Court delivered his opinion in three cases concerning the extension of the tax sparing credits under the tax treaties with Brazil and Greece to third countries pursuant to the most-favoured nation principle and the Community preference.
(a) Facts. In Case 43.507, the taxpayer was the pare…
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