In this article, the author seeks to illustrate, through examples dealing with cross-border business losses, what the result would be if Member States were to subject non-resident taxpayers to unlimited income taxation whilst granting double tax relief under a Netherlands-style tax exemption method.

Fiscal Autonomy and its Boundaries
Bulletin for international taxation
Erasmus School of Law

de Wilde, M. (2011). What if Member States Subjected Non-Resident Taxpayers to Unlimited Income Taxation whilst Granting Double Tax Relief under a Netherlands-Style Tax Exemption?. Bulletin for international taxation , 1–14. Retrieved from