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Please explain to me what the term Dutch Sandwich means?

Topics: Netherlands Tax
12 weeks ago, Netherlands Viewed 242 times
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Hendrik Van Duijn
A Dutch Sandwich is a CV/BV structure. It is often used by US companies to mittigate their overall tax position. CV is checked as a reverse hybrid (a company) and the BV is considered a flow-through entity for US tax purposes. Thus from a US tax perspective the transactions between the CV and the BV are not recognised.

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