OrbitaxSupreme Court – Reinvestment reserve of subsidiary taxable at level of parent company in fiscal unity
|Approved Changes|Netherlands
On 9 November 2012, the Netherlands Supreme Court (Hoge Raad der Nederlanden) gave its decision in case number 11/05078, on whether or not a subsidiary's reinvestment reserve (herinvesteringsreserve), upon removal of that subsidiary from a fiscal unity, is taxable at the level of the parent company. Details of the decision are summarized below.
(a) Facts. The Taxpayer (the pa…
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