Dutch Appeals Court Issues Decision on Currency Exchange Rates for Back-to-Back Dividends Payment Transactions

The Amsterdam Court of Appeal has recently issued a decision regarding the currency exchange rates to be applied for a back-to-back dividend payment transaction in relation to the Dutch participation exemption.
The case concerned a multinational group of companies and back-to-back payments of a CHF 104 million dividend in 2011 as part of the group's plan to eliminate intragroup loans from gro…
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