Russian Interest Payments Limited by Thin Cap Rules Not Exempt under Dutch Participation Exemption Rules
On 5 June 2019, the Lower Court of North Holland gave its decision in case no. 17/871 on the impact of the Russian thin capitalization rules on the application of the Dutch participation exemption based on article 9 of the Netherlands - Russia Income and Capital Tax Treaty (1996). Details of the case are summarized below.
Summary
The taxpayer, a Dutch BV had made loans to a Russian related c…
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