Taxence

Opinie | De indirectebezitseis in de BOR

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A Dutch Supreme Court ruling (January 30, 2026) clarifies the indirect ownership requirement for the Business Operations Exemption (BOR). The key requirement: a company whose shares are gifted must have operated a business for at least five consecutive years. Professor Philippe Albert analyzes critical aspects of this indirect ownership criterion and its implications for tax planning and corporate gifting strategies.