Lower Court of The Hague decided parent company of group not holding company for purposes of Tax Regulation of the Kingdom

On 15 June 2007, the Lower Court of The Hague decided a case on the classification of the parent company of a group of companies (fiscal unity) as a "holding company" for the purposes of the Tax Regulation of the Kingdom (TRK).
(a) Facts. The taxpayer (BV X) was formed in the Netherlands and until 1 January 1999 established in the Netherlands; thereafter, its stat…
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