Position Papers of the Dutch Tax Authorities
Position of the Dutch tax authorities on the application of the liquidation loss scheme in case of the dissolution and liquidation of an entity that previously was a sub-subsidiary of the taxpayer
On March 28, 2024 on the website of the Dutch tax authorities a position paper of the Knowledge Group participation exemption answered the question what the amount of liquidation loss to be taken into account amounts to in the event of the dissolution and liquidation of a former sub-subsidiary (KG:023:2024:4). Prior to this dissolution and liquidation, this sub-subsidiary incurred a loss on the alienation of its subsidiary (a sub-sub-subsidiary of the taxpayer). Subsequently (direct) subsidiary of the taxpayer was dissolved and liquidated, as a result of which the shares of the (former) sub-subsidiary came into the possession of the taxpayer.