review of the main purpose, minimum participation period of 365 days for dividends, etc.) will probably be included in the renegotiated treaty. The DBA applies to income taxes and aims to prevent double taxation and tax evasion. For Hong Kong, this DBA is the first tax agreement with an OECD member country that applies the latest international standard for the exchange of information. The DBA contains a provision on the exchange of information on tax matters, in accordance with OECD standards. It allows the tax authorities of Hong Kong and the Netherlands to consult with each other to settle disputes relating to the application or interpretation of the DBA. In addition, taxpayers could apply for an agreement procedure (and, ultimately, arbitration) under the DBA if actions of one or both countries result in taxation that is not in compliance with that DBA. Countries with which the Netherlands is currently negotiating double taxation treaties: De Jager: „I am very pleased that we have signed this agreement today. This is a milestone in bilateral relations between Hong Kong and the Netherlands and a springboard to further increase mutual investment. The DBA contains a specific anti-abuse provision, which states that the agreement does not affect the right of each state to apply its national legislation and anti-tax avoidance measures, whether or not they are designated as such. For the Netherlands, reference is made to the taxation of non-residents, which is based on the rules on substantial participation (aanmerkelijk belang) laid down in the Netherlands Corporate Tax Act. On 22 March 2010, Professor K.C Chan, Secretary of Financial Services and the Hong Kong Ministry of Finance, and Mr.

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