In this article, the author examines, through examples, the effects of Member States subjecting taxpayers to unlimited income taxation whilst granting double tax relief under a Netherlands-style tax exemption from the perspective of how such an approach would affect the cross-border taxation of intra-firm transactions.

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

de Wilde, M. (2011). Intra-Firm Transactions: What if Member States Subjected Taxpayers to Unlimited Income Taxation whilst Granting Double Tax Relief under a Netherlands-Style Tax Exemption?. Bulletin for international taxation , 65(12), 1–17. Retrieved from