On 13 January 2013, the Netherlands Supreme Court (Hoge Raad der Nederlanden) gave its decision in X BV. v. Staatssecretaris van Financiën (No. 12/01616, LJN:BY0612), which was recently published. The case concerned the deductibility of alienation expenses for the sale of a substantial shareholding. Details of the decision are summarized below. (a) Facts. X BV (the Taxpayer), formed a fiscal unity with a 100%-owned subsidiary. On 21 November 2008, all shares of the subsidiary were sold and the fiscal unity was dissolved. The Taxpayer made costs for the sale of the subsidiary. Those costs were incurred after the signing of...