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Treaty between Netherlands and Spain – mutual agreement on application of treaty to investors in Dutch closed fund for mutual account

04 May 2013

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Treaty Development

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Netherlands; Spain

In a press release of 6 February 2013, it was announced that the competent authorities of the Netherlands and Spain on 18 December 2012 have signed a MAP, regarding the application of the Netherlands - Spain Income and Capital Tax Treaty (1971) to investors in a closed fund for mutual account (fonds voor gemene rekening (closed FGR)) established in the Netherlands. Details of the agreement, which applies from 1 January 2013, are summarized below. Qualifying FGRs The agreement applies to closed FGRs and umbrella funds consisting of several closed FGRs formed in conformity with Dutch civil and tax law, acting as a pooled...