On 30 November 2012, the Dutch Supreme Court (Hoge Raad der Nederlanden) gave its decision in X Management BV v. the Tax Administration (Case No. 11/00167; LJN: BV 7390) on the application of the business merger facility to a contribution to a newly established subsidiary followed by subsequent contribution to a newly established daughter company of all of the assets except a business building. Details of the case are summarized below. (a) Facts. In 2003, the taxpayer established a holding company (D BV) and contributed all business assets including a business building to that company. Subsequently, in 2003, the holding company established a...