"The Caribbeans are thinking about trading profits, not royalties, so the smaller European countries like Holland have had to be creative, tax-wise," said David Pullman, an investment banker in New York who caters to entertainers and athletes. "They are going for the high- end stuff and don't want to be seen as shady like some Caribbean haven."

Many of the world's multinational corporations, like Coca-Cola, Nike, Ikea and Gucci, have set up holding companies here in recent years to take advantage of tax shelters nearly identical to the ones the Rolling Stones and U2 use. An additional draw is the Dutch Finance Ministry's recent willingness to issue advance rulings that effectively bless the tax shelters, a fast-track process that has lured companies and individuals.

Sun Microsystems, the U.S.-based software and computer manufacturer, operates Dutch holding companies and is candid about why it does so.

Until recently, on the Web site of the Netherlands Foreign Investment Agency, www.nfia.com, Sun offered the following blurb about the country's accommodating tax laws:

"Let's face it: ask foreign companies why they're really located here, and nearly everyone will reply that it's because of the favorable tax ruling. The combination of this with the country's political stability, well-trained labor force, their linguistic skills and international attitude as well as the stable infrastructure for roads and telecommunications — this is why we're here." A Sun spokeswoman declined to comment.

The Netherlands is home to almost 20,000 "mailbox companies," Dutch shorthand for corporate shells set up by foreign companies and wealthy foreigners who use them to reduce taxes on royalties, dividends and interest payments, according to a report issued in November by SOMO, the Dutch initials for the Center for Research on Multinational Corporations, a nonprofit group in Amsterdam that monitors business practices of large companies. Globally, 1,165 companies use Dutch tax shelters to reduce or eliminate taxes on royalties and patents, according to SOMO.

Like the Rolling Stones, U2 has become sophisticated about finding overseas shelters for its money. When Ireland announced last spring that it would sharply curtail a tax break for musicians, painters, writers and sculptors, the shift posed a financial threat to U2, which had Ireland as its financial power base for nearly three decades. The Dublin-born- and-bred rockers built their fortune on hit songs and, in part, on Irish laws that forgive taxes due on royalties.

As of last year, U2 had amassed a net worth of €629 million, or $908 million, according to the annual "Rich List" of top earners in The Sunday Times of London. Royalties are the income that artists and athletes earn from recordings, performances, trademarks, brands, patents, copyrights, film rights, product endorsements, videos, films and the ever-extending commercialization of those assets — in short, the major portion of an artist's or athlete's income.