On 5 June 2007, the Advocate General (AG Wattel) of the Netherlands Supreme Court delivered his opinion in three cases concerning the extension of the tax sparing credits under the tax treaties with Brazil and Greece to third countries pursuant to the most-favoured nation principle and the Community preference. (a) Facts. In Case 43.507, the taxpayer was the parent company of a group of companies (fiscal unity). The subsidiaries of the group held participations in, and had debt claims on, companies established in Belgium. In 2001, the subsidiaries received interest income due under those debt claims to an amount of...