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Dutch Supreme Court Rules on Interest Deduction Limitation Rules in Private Equity Structures

|Approved Changes|Netherlands
Netherlands

On 15 July 2022, the Dutch Supreme Court issued rulings in two similar cases involving the application of the interest deduction limitation rules in private equity structures. Both cases/structures involved investments in Dutch target companies through Dutch acquisition holding companies held by Luxembourg holding companies. To finance the investments, the Luxembourg holding companies issued preferred equity certificates to the investment fund vehicles and co-investors. The proceeds from the …

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