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Case Law
Introduction to translations
Dividend tax: Emigration of BVIs distribution made shortly after emigration from NL free from dividend tax?
Dividend tax: Temporary repuchase of sharesThe purpose of the repurchase and not the accounting treatment is determinitive
EC Merger DirectiveDoes merger of investment companies qualify for merger directive?
EC Merger DirectiveSeries of transactions prevents application of share merger facility
EC Treaty:BCC loansIs BCC taxation reasonable by Dutch standards and is article 10a EU compliant?
EC Treaty: De Groot CaseApplication Dutch Supreme Court of ECJ decision
EC Treaty:Dutch mutual investment fundsAre the limitations on foreign investments and investors EU compliant?
EC Treaty: Loss from liquidationParticipation exemption regime re. liquidation loss contravenes EU law
Interest deductions: BCC loansIs BCC taxation reasonable by Dutch standards and is article 10a EU compliant?
Interest paid: Meaning under tax treatiesCan NL tax deemed interest income of Belgian resident as interest paid?
Interest deductions: Perpetual loansIs loan redeemable in 2210 still a loan?
Loss compensation: Losses from liquidationDeferring liquidation until after transfer of substantial interest may not help
Participation exemption: Falcon Case, stock optionsInteraction options and the participation exemption
Participation exemption: 3% ParticipationIs participation exemption applicable
Participation exemption: US LLCIs participation exemption applicable
Participation exemption: Loss from liquidationLiquidation loss regime contravenes EU law
Participation exemption: Pret participatif High Court; Supreme CourtDoes the income from a pret participatif qualify for the participation exemption
Statute of limitationSometimes 12 years instead of 5
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