Wilde, M.F. de

income taxpayer dutch state business netherland taxation court group purpose exemption source justice activity system tax treatment regime johnson approach respect business activities company tax burden scenario capital worden fiscale resident market business income branch currency consolidation entity tax purposes burden profit interest eu mss mechanism application section eu member states credit treatment tax systems participation principle draft dutch tax tax base effect tax consolidation currency exchange results exchange amount result tax system nederland subject relief wordt asset resident taxpayers comparison jurisdiction place groep eu ms buitenlandse basis group companies obstacle residence onder member example proceed transfer winst