Tracing the Origins of the Netherlands’ Tax Treaty Network

Intertax, Vol. 41, Issue 6/7

15 Pages Posted: 25 May 2013

See all articles by Maikel Evers

Maikel Evers

Erasmus University Rotterdam (EUR) - Erasmus School of Law

Date Written: May 24, 2013


This contribution identifies the main determinants and key persons that constituted the tax treaty policy of the Netherlands. This policy is rooted in the political chess games in 19th century mainland Europe. In this century, European states gained experience in negotiating trade and tax agreements. Not only were the Germans experts in divide and rule strategies; they also developed instruments that form the core of contemporary tax treaty law. Dutch tax treaty policy blossomed when the Netherlands opened tax treaty negotiations with Germany. Negotiations that followed an erratic course, making their mark on the notorious tax treaty policy of the Dutch. The Dutch legislator refined the tax system to support a fruitful tax treaty policy, focusing on becoming an intermediary state for international investment. However, the firm position of the Dutch on bank secrecy had thrown a spanner in the works. Finally, the erratic course of these early tax treaty negotiations inspired the League of Nations tax committees through some of their key members.

Keywords: Tax treaties, DTAs, Netherlands, conduit, bank secrecy, international tax policy, permanent establishment, coalition externalities

JEL Classification: H20, K34, N40

Suggested Citation

Evers, Maikel, Tracing the Origins of the Netherlands’ Tax Treaty Network (May 24, 2013). Intertax, Vol. 41, Issue 6/7, Available at SSRN:

Maikel Evers (Contact Author)

Erasmus University Rotterdam (EUR) - Erasmus School of Law ( email )

3000 DR Rotterdam

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