Israeli Tax Alerts | Practical Interpretations | 2008-2020
64 the fact that the dividend is “returned” to the tax base. As opposed to this, if we say that Israel does not absorb the income classification of the Treaty Country, it may then be claimed that the income constitutes interest despite the Dutch classification and, as stated, interest is not “returned” to the tax base; therefore, CFC provisions shall not apply. (December 2017)
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