Koninklijke Luchtvaart Maatschappij N.V. (hereinafter “KLM”) is a Dutch airline, headquartered in Schiphol. Among others it has two employees: Bill and Bob. Bill is a financial controller, and Bob is an analyst. While Bill works at the Schiphol airport, he actually lives in Antwerp, driving to work every day and back every night. Bob also lives in Antwerp, and drives most days to Schiphol. However, as he is an analyst he can do quite a lot of work from a secondary office of KLM at Brussels’ Airport. Thus, about a third of the time he actually works in Brussels. There is an OECD-style double tax convention in place between Belgium and the Netherlands (the terms of the convention correspond exactly to the model).

1. Which country gets Bill’s payroll taxes? Does it depend on the type of tax?

1. Which country gets Bob’s payroll taxes? Does it depend on the type of tax?