An Expat sent to The Netherlands chooses to be treated as a Partial Non-Resident Taxpayer. Does he now qualify as a resident of The Netherlands for purpose of tax treaties with the standard OECD residency article?

/An Expat sent to The Netherlands chooses to be treated as a Partial Non-Resident Taxpayer. Does he now qualify as a resident of The Netherlands for purpose of tax treaties with the standard OECD residency article?

An Expat sent to The Netherlands chooses to be treated as a Partial Non-Resident Taxpayer. Does he now qualify as a resident of The Netherlands for purpose of tax treaties with the standard OECD residency article?

Yes, an Expat (other than US Expat) sent to The Netherlands who chooses to be treated as a Partial Non-Resident taxpayer qualifies as a resident of The Netherlands for all tax treaties that use the standard OECD residency article.

Technical reference (for tax professionals): Secretary of Finance, August 23, 2013, question 5.