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Netherlands - Restriction on Interest Deductibility for Dutch Holding Companies

Country:
Netherlands
Author:
N. Vis
Issue:
European Taxation, 2013 (Volume 53), No 6
Published:
7 May 2013
As per 1 January 2013, new legislation restricts the deductibility of interest on excessive debt used to finance participations. An intention test has been introduced that addresses situations in which the acquisition of a participation is structured via a Dutch taxpayer for the purpose of obtaining an interest deduction in the Netherlands. This note discusses the intention test, in particular the circumstances under which a Dutch holding company can meet this test.
 
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