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

Tax Controversy & Dispute Resolution ()

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.