The Dutch Supreme Court Reaffirms and Clarifies ‘de facto employer’ under Article 15 of the OECD Model - Intertax View The Dutch Supreme Court Reaffirms and Clarifies ‘de facto employer’ under Article 15 of the OECD Model by - Intertax The Dutch Supreme Court Reaffirms and Clarifies ‘de facto employer’ under Article 15 of the OECD Model 36 2 Intertax