Grams, H.

artiste article state sportsmen taxation treaty performance income tax treaties model withholding withholding tax oecd model netherland country dutch football european article 17 expense football club feyenoord residence problem molenaar member exception feyenoord right tax credit european union credit source commentary uk football clubs decision example x case freedom performance fees tax treaty member states authority union return scorpio residence state service league europe league situation performance fee sportsman ecj x case champions league market dutch supreme court issue tax treaty policy dutch tax authorities principle paragraph obstacle section result treatment provision group harald grams freedom principles income tax convention intertax exchange section 14 belgium ecj decisions dutch theatre company payment regard eu member states