A decision of Lower Court Haarlem of 17 December 2007 (Case No. 06/1645 and 06/1646) was recently published. It concerned the levy of an exit tax as a result of the transfer of the central management and control of a Dutch company to the United Kingdom. Details of the case are set out below.
(a) Facts. The taxpayer (X NV) is part of the Y group, which owns electricity and gas networks in the United Kingdom and the United States. Its shares were held by Y Holding BV. X B…