A US 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 the 1992 tax treaty between the USA and The Netherlands?

/A US 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 the 1992 tax treaty between the USA and The Netherlands?

A US 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 the 1992 tax treaty between the USA and The Netherlands?

No, an expat with US nationality or holder of a US Greencard will not be taxed as a resident in The Netherlands for purpose of the tax treaty. The United States regard him as a resident of the US, therefore the US Expat doesn’t qualify as a resident of The Netherlands.

Employment income earned in The Netherlands for an employer registered for the Payroll Tax in The Netherlands is assigned to The Netherlands.

Technical reference (for tax professionals): Secretary of Finance, August 23, 2013, question 4.