The Amsterdam Court of Appeal has recently issued a decision regarding the currency exchange rates to be applied for a back-to-back dividend payment transaction in relation to the Dutch participation exemption.
The case concerned a multinational group of companies and back-to-back payments of a CHF 104 million dividend in 2011 as part of the group's plan to eliminate intragroup loans from group members' books. The transaction involved the payment of the dividend on 4 August 2011 to an inter…