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If a firm has significant business in a third party jurisdiction it is often possible to reduce the overall tax position by transferring management and control to a more tax efficient area.
For example, if a Dutch firm purchased a given type of good in Italy for resale to the Middle East it would seem inappropriate to say the least that such a transaction should be subject to Dutch corporation tax.
A potential solution would be to set up a company in a low tax area such as the Netherlands Antilles to specifically control these transactions. If this is done correctly and does not offend the anti-avoidance provisions it should be possible to benefit from for example the Netherlands Antilles corporate tax regime.
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