Author Description

This thesis contains the results of research with respect to the international aspects of the Dutch substantial interest rules, as laid down in chapter 4 and part 7.3 of the Individual Income Tax Act 2001. The research concerns the rules with respect to emigration, immigration and remigration of the holder of a substantial interest, as well as the tax liability of non-resident tapayers in connection with the residence fiction and the seat-transfer levy. The emphasis has been put on two exit levies and the residence fiction relating to non-resident taxpayers.