Dutch tax court finds for Dutch tax administration in captive insurance company case

Tax Insights ()

Introduction

In our PKNs of May 4, 2009 and July 23, 2009 we reported on the UK Dixons case. Last year a Dutch lower court has issued a ruling relating to the transfer pricing arrangements between a Dutch holiday resort and its Irish captive insurance company. The holiday resort operates a large number of holiday houses. At the time of reservation, tourists can buy cancellation insurance which the resort subcontracts to its captive insurance company in Ireland.