On 6 December 2013, the State Secretary for Finance submitted to the parliament amendments (No. 33 713, numbers 5 and 6) to the legislative proposal to codify the "compartmentalization" of income derived under the participation exemption regime. The amendments concern (the proposed) article 28c(4)(a) of the Dutch Corporate Income Tax Law 1969 (CITL). This provision sees to the treatment of existing compartmentalization reserves in the event of a (partial) sale of the underlying participation. Specifically (but not exhaustively), the provision mentions the transfer of the shares in the context of a merger or a division, as well as the formation...