ARTICLE · 05 DECEMBER 1995
Permanent Establishment in the Netherlands - Danish Tax Treaty
NetherlandsAccounting and Audit
KPMG Meijburg & Co, the Netherlands comments on the term permanent establishment in the Netherlands-Danish tax treaty of February 20, 1957.
This is contribution number 20 by KPMG Meijburg & Co regarding the term permanent establishment in the Netherlands-Danish tax treaty of February 20, 1957.
Resolution of September 6, 1995, no. IFZ95/1091M
On September 6, 1995, the Dutch Ministry of Finance issued the following statement.
Article 2, first paragraph, section f of the 1957 tax treaty between the Netherlands and Denmark provides only a brief description of the term 'permanent establishment'. The treaty does not contain the more or less standard rule for construction or installation activities. This deviation from the OECD Model Treaty and from the great majority of Dutch tax treaties caused some confusion. It has been agreed with the competent Danish authorities that the execution of a work or of construction or installation activities will qualify as a permanent
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