Mees Vergouwen, Author at Kluwer International Tax Blog

The UTPR and the (disguised) discrimination under tax treaties

Błażej Kuźniacki ( PwC Netherlands, Lazarski University and Singapore Management University) and Mees Vergouwen (Assistant professor at Leiden University and tax advisor at De Brauw Blackstone Westbroek, Amsterdam. )/March 21, 2025March 25, 2025 /Leave a comment

The authors are winners of the Mitchell B. Carroll Prize for the last two consecutive years, as awarded at the International Fiscal Association global congresses in 2023 and 2024 in Cancún (Mexico) and Cape Town (South Africa), respectively.* The compatibility of the Undertaxed Profits Rule (UTPR) with tax treaties based on the OECD or the…

Directive, EU law, OECD, Pillar II

The subordination clause in the new tax treaty between the Netherlands and Belgium that grants primacy to the Pillar 2 Directive

Mees Vergouwen (Assistant professor at Leiden University and tax advisor at De Brauw Blackstone Westbroek, Amsterdam. )/July 13, 2023July 13, 2023 /Leave a comment

Mees Vergouwen[1] On 21 June 2023, the Netherlands and Belgium signed a new tax treaty.[2] Part of (the protocol to) this tax treaty is a subordination clause[3] that provides that “nothing in this treaty shall prevent the application (…) of Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of…