Supreme Court considers that Box 3 taxation is still contrary to the ECHR and drafts compensation scheme
The Supreme Court concluded that tax assessments must be reduced so that only the actual return is taxed in Box 3, and it also provides rules for determining the actual return.
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 ...