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

|Treaty Development|Netherlands-Curacao
Netherlands-Curacao

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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