Details of the income tax treaty and protocol between Panama and the Netherlands, signed on 8 October 2010, have become available. The treaty was concluded in the Dutch, English and Spanish languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention. The maximum rates of withholding tax are: -   15% on dividends generally. However the rate is 0% if: (i)   the beneficial owner is a company which owns directly at least 15% of the capital of the company paying the dividends, and (a) the...