Dutch Supreme Court judgment on the crediting of dividend withholding tax
On January 19, 2024 the Dutch Supreme Court clarified the rules applying to the crediting of dividend withholding tax for corporate income tax purposes.
Among other things, the possibilities for setting off holding company losses have been limited and the permanent establishment concept has been expanded for the purposes of withholding tax on interest ...
The Supreme Court based its conclusion on a formal interpretation of the term ‘interest’ in the Legal Transactions Taxation Act and thus ruled differently to the Court of Appeals ‘s-Hertogenbosch, whi ...
