Casenote - withholding tax on repo transactions, and the tax-free treatment of TKs under the Netherlands-Japan treaty

The authors examine two recent court decisions. The first is a decision on withholding tax paid (and additional tax in respect of non-payment of the withholding tax) with regard to repurchase transactions conducted in overseas markets, while the second involves the question of whether income from a silent partnership should be eligible for tax-free treatment under the Netherlands-Japan Tax Treaty.