Si j’ai bien compris, le « #sandwich_hollandais » ne sert pas seulement à ne pratiquement pas payer d’#impôts ▻http://www.leparisien.fr/espace-premium/fait-du-jour/google-et-la-technique-du-sandwich-hollandais-19-11-2012-2334007.php mais aussi à voler les avoirs des #Etats ►http://www.ipsnews.net/2015/12/french-firm-attacks-ugandan-tax-using-isds ?
The problem Uganda now faces has been made possible by the Bilateral Investment Treaty signed in 2000 with the Netherlands. According to the treaty, all Dutch investors in Uganda have the right to pursue arbitration before the World Bank court if they feel treated unfairly. The French company #Total Uganda registered itself as a Dutch company.
This is known as the #Dutch_Sandwich; you put a Dutch company in between and then you become a Dutch investor. Which turns the treaty into a tool to drag a state before a #tribunal of three men in Washington, having a commercial background and the ability to award billion dollar fines, without a possibility to appeal. If Uganda is condemned to a compensation but refuses to pay, the company has the right to seize Ugandan assets in the world.