Recent Developments in the Dutch Loss Carry Over Restrictions for Holding and Intercompany Financing Entities

• Autores: Arthur W. Hofman, Shie Yee Au Yeung
• Localización: Intertax, ISSN 0165-2826, Vol. 44, Nº. 6-7, 2016, págs. 559-563
• Idioma: inglés
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• Resumen

  • Based on Dutch tax law, losses resulting from holding and financing activities are ring-fenced in such a way that these losses can only be offset against profits derived from similar activities. Recently, two developments took place with regard to those rules. First, the Dutch tax law was changed in reaction on a verdict of the Dutch Supreme Court. Second, the European Court of Justice (ECJ) ruled a verdict that could have an impact on the rules. In this article, the authors describe those developments and they discuss the current scope of the relevant Dutch legislation.