On 15 July 2022, the Dutch Supreme Court issued rulings in two similar cases involving the application of the interest deduction limitation rules in private equity structures. Both cases/structures involved investments in Dutch target companies through Dutch acquisition holding companies held by Luxembourg holding companies. To finance the investments, the Luxembourg holding companies issued preferred equity certificates to the investment fund vehicles and co-investors. The proceeds from the equity certificates were used to fund the Dutch acquisition holding companies through equity and shareholder loans. In the structure, the Dutch acquisition holding companies acquired all shares in the target companies, forming...