On 14 June 2013, it was announced that the State Secretary for Finance will present to the Parliament a legislative proposal to codify the so-called "compartmentalization" of income derived under the participation exemption regime. Generally, the compartmentalization principle refers to the attribution of income in situations where the same income (e.g. dividends or capital gains) is treated differently for tax purposes as a result of a legislative change. This principle, however, was never codified in Dutch domestic law. The announcement was made after the Supreme Court of the Netherlands (Hoge Raad der Nederlanden), on that same day, gave its decision...