Belastingdienst: standpunten DSR en BOR voor tracking stocks

The Dutch Tax Authority has published positions on the pass-through ruling (DSR) and business succession scheme (BOR) regarding the allocation of business assets for tracking stocks held directly and indirectly. The Knowledge Groups on substantial interest and inheritance law clarified how business assets should be attributed under articles 4.17a-4.17c of the Income Tax Act 2001 and articles 35b et seq. of the Inheritance Tax Act 1956 for these specific investment structures.