On 14 March 2024, an opinion was issued from Advocate General (AG) Emiliou of the Court of Justice of the European Union (CJEU) in response to a request for a preliminary ruling from the Hoge Raad der Nederlanden (Supreme Court of the Netherlands) concerning Dutch limitations on the deduction of interest and the freedom of establishment (Article 49 TFEU). In particular, the Supreme Court seeks a preliminary ruling regarding the interest deduction limitation rule under Article 10a of the Corporate Income Tax Act (CITA) that concerns related party financing for the acquisition of an entity that becomes a related party...