By notification IFB 05-01 of 23 December 2005, the Netherlands Ministry of Finance announced that the tax sparing credit regime in respect of dividends, interest and royalties granted under the Netherlands-Malaysia income tax treaty and related protocol of 7 March 1988 and the amending protocol of 4 December 1996 ceased to apply with effect from 1 January 2006. Specifically, Art. 23(4) of the Netherlands-Malaysia treaty and Art. VI of the 1996 Protocol provided for a tax sparing credit on dividends, interest and royalties equal to the tax that would have been withheld if no exemption would be applicable in Malaysia....