On 13 January 2013, the Netherlands Supreme Court (Hoge Raad der Nederlanden) gave its decision in X BV. v. Staatssecretaris van Financiën (No. 12/01616, LJN:BY0612), which was recently published. The case concerned the deductibility of alienation expenses for the sale of a substantial shareholding. Details of the decision are summarized below.

(a) Facts. X BV (the Taxpayer), formed a fisc…

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