Tax Bulletin

2009 Year End Tax Bulletin

Introduction

This Year End Tax Bulletin summarises the most significant tax developments that took place in the Benelux region during 2009 and highlights the main legislative changes announced for 2010. It focuses on developments and changes that are relevant for internationally operating enterprises. Given the general nature of this Year End Tax Bulletin, the information contained in this publication should not be regarded as a substitute for detailed legal advice. You are however most welcome to contact us if you would like to receive more information on any of the below topics.

The Netherlands

Applicable Dutch corporate income tax rates for 2010 and 2011
The Dutch corporate income tax rates for 2009 and 2010 were temporarily adjusted (with retroactive effect to 1 January 2009) to 20% for a taxable amount up to € 200,000 to provide companies a cash benefit during the economic crisis. As of 2011, this measure will be reversed and the pre-2009 rates should again be applicable.

Taxable amount (€)		Rates for 2009	Rates for 2010	Rates for 2011
-	40,000	20.0%	20.0%	20.0%
40,000	200,000	20.0%	20.0%	23.0%
200,000	-	25.5%	25.5%	25.5%

Extension of accelerated and random depreciation
In 2009, the Dutch government decided to temporarily reintroduce the possibility for accelerated and random depreciation of business assets to stimulate investments. Investments in most assets made between 1 January 2009 and 31 December 2009 may be depreciated in two years, with a maximum of 50% in 2009 and 50% in 2010. The 2010 Tax Budget extends this regime for one additional year, i.e. investments made between 1 January 2010 and 31 December 2010 can benefit from accelerated and random depreciation in 2010 and 2011. The accelerated and random depreciation is applicable to most business assets (exceptions apply to amongst others buildings, certain infrastructure projects, immaterial fixed assets and assets acquired to be leased to third parties).

Changes to the tonnage tax scheme
Currently, the tonnage tax scheme can be applied to profits derived from the exploitation of a ship in international traffic by sea, which is generally interpreted as transport by sea. The Dutch government has proposed to broaden the scope of the tonnage tax scheme as per 1 January 2010 (provided approval will be obtained from the European Commission) by including profits derived from the exploitation of a ship that transports people and/or objects for the purposes of (i) laying cables and pipelines, (ii) exploration of the sea-bed or (iii) heavy lifting at sea. Please note that only profits relating to the transport fall within the scope of the tonnage tax scheme, i.e. profits derived from the laying of cables and pipelines, the exploration or the heavy lifting itself are explicitly excluded.

New Innovation box regime
One of the eye-catching measures in the 2010 Tax Budget is the improvement of the current patent box. Since 1 January 2007, companies can opt to include their net proceeds from self-developed, patented intangibles in the patent box where the proceeds are effectively taxed at a reduced corporate income tax rate of 10%. In 2008, the patent box was extended to also include net proceeds from intangibles for which a so-called R&D statement (see below) was obtained. As of 1 January 2010, in addition to renaming the patent box “innovation box”, the following three improvements will be made:

The effective tax rate for the box is reduced from 10% to 5%.
The total net proceeds taxable at the innovation box rate is no longer capped (previously amongst others a cap of four times the total amount of R&D expenses of the intangible assets applied).
Where in a certain year the net proceeds from qualifying intangible assets are negative, the loss is deductible from the taxable profit against the regular rate. However, such loss must first be recaptured against the regular tax rate before the reduced innovation box rate is applicable again.

In addition to these improvements, the facility for R&D wage tax credits is extended enabling companies to claim a larger wage tax credit. To be eligible for an R&D wage tax credit, a so-called R&D statement needs to be obtained with SenterNovem (which is part of the Dutch Ministry of Economic Affairs). To qualify for such R&D-statement, a project should focus on e.g. the development of technically new products or production processes.

From recent discussions we had with the tax authorities and practical experience with the patent box, it follows that the tax authorities will apply a very pragmatic approach when considering applications for the innovation box. In essence, the amount of profit allocable to the box can be determined on the basis of a profit split of the commercial EBIT. In view of the improvements and the pragmatic approach from the tax authorities, the Dutch innovation box has become an attractive tax planning tool for international businesses.

Changes in carry forward and carry back of tax losses
To increase the cash position of companies, two changes were made to the carry forward and carry back of tax losses:

Taxpayers can claim loss relief on the basis of a reasonable estimation of their losses for the current tax year. This means that taxpayers no longer have to first file a tax return and have to wait until the tax authorities issue a final tax assessment before relief (e.g. through carry back of the loss to prior years) can be granted.
In their annual corporate income tax return, taxpayers can opt for an extension of the loss carry back period from one to three years. This option is available for losses incurred in the taxable years 2009 and/or 2010. Election is subject to two limitations: (i) if you elect for this extension the maximum loss carry forward period will be reduced from nine to six years and (ii) the maximum amount of tax losses to be carried back to the second and third year preceding the loss year will be limited to € 10,000,000 for each year.

Changes to the Dutch participation exemption
General
The Dutch participation exemption does not apply to "low-taxed investment participations". Under current rules, this regards (in brief) participations in a subsidiary of which the directly and indirectly owned assets consist of more than 50% portfolio investments (the “Asset Test”) and which is taxed in its state of residence at an effective tax rate of less than 10% (the “Tax Test”). The Asset Test and the Tax Test will remain in place in slightly amended form and, in addition, the 2010 Tax Budget reintroduces a motive test (as defined below) that was abolished as per 2007. As of 2010, the Dutch participation exemption will be applicable to a participation if it fulfils at least one of these three tests.

The Motive Test
As of 2010, the main rule will be that the participation exemption applies to a participation of at least 5% in a subsidiary, unless such participation itself is held as a portfolio investment (the "Motive Test”). The rather open-ended description of the Motive Test, as developed in Dutch case law prior to 2007, requires a determination as to the taxpayer’s objective of owning the participation. The Motive Test is not satisfied if the taxpayer only aims at earning a yield that is similar to the yield that can be expected from normal, active portfolio asset management. If the taxpayer has more than one motive (e.g. the subsidiary is partly held as a portfolio investment and partly for business reasons), the predominant motive is decisive.

The Motive Test is generally satisfied when the business carried on by the subsidiary is similar or complementary to the business carried on by the Dutch taxpayer. In the past, Dutch tax authorities also accepted that the Motive Test was satisfied when the taxpayer did not carry on a business of its own, but instead played an essential role in the business of the group because of its activities in terms of management, strategy or finance. Further, the Motive Test was satisfied if the Dutch taxpayer was an intermediary holding company that acted as a link between the ultimate parent and operating subsidiaries. The legislative change means a return to this practice.

The Motive Test is deemed not to be met if (i) more than half of the subsidiary’s consolidated assets consist of shareholding(s) of less than 5% or (ii) the predominant role of the subsidiary – together with the roles performed by its lower tier subsidiaries – is to put cash or assets at the disposal of other group entities, for example to act as a group finance company.

The Asset Test
The Asset Test will not change substantially. As under current law, the Asset Test will be met if the taxpayer demonstrates that less than 50% of its directly and indirectly held assets consist of low taxed portfolio investments. Here, group receivables are still deemed to be portfolio investments, unless (i) the participation qualifies as an active group finance company, (ii) the receivables are mainly financed (90% or more) from third party debt, or (iii) income of the receivables is subject to sufficient taxation (same meaning as for purposes of the Tax Test – see below). An improvement to the current Asset Test is that real estate and assets used in an active leasing business are no longer deemed to be portfolio investments.

The Tax Test
The Tax Test will not change substantially either. The current condition that a participation is considered sufficiently taxed if it is subject to an effective tax rate of at least 10%, calculated according to Dutch tax standards, will be replaced by the condition that the participation is subject to a "realistic levy" in its state of residence. It was indicated in parliament that an effective tax rate of at least 10% is sufficient for passing this test. However, the revised Tax Test means that a full recalculation to Dutch tax standards of the taxable profits of the participation in principle is no longer required.

Amendments to the Dutch dividend tax
As a consequence of the decisions of the European Court of Justice in Commission v. the Netherlands (Case C-521/07) and Aberdeen Property Fininvest Alpha Oy (Case C-303/07), the 2010 Tax Budget extends the current dividend tax exemption. The exemption can now also apply to dividends paid to companies resident in Iceland and Norway that have a shareholding of at least 5% in the Dutch distributing company. Even though Liechtenstein has recently entered into an Exchange of Information Treaty with the Netherlands, shareholders resident in Liechtenstein are still excluded from the dividend tax exemption. Furthermore, for application of the dividend tax exemption it is no longer required for shareholders established in the European Union or the European Economic Area (i) to have a legal form listed in the Annex to the EU Parent Subsidiary Directive or (ii) to be subject to a profit-based tax as listed in the EU Parent Subsidiary Directive. However, the dividend tax exemption remains inapplicable if the shareholder is subject to a tax regime similar to the Dutch fiscal investment institution or Dutch tax-exempt investment institution regime.

Status of the Consultation Document
On 15 June 2009 the Dutch Ministry of Finance published a consultation document proposing changes to the Dutch Corporate Income Tax Act 1969, amongst others into the tax treatment of interest (the ”Consultation Document”). The Consultation Document suggests the idea of a mandatory group interest box and two alternative interest deduction restrictions. It invited interested parties to provide comments to the proposals. On 2 September 2009, the State Secretary of Finance indicated that 87 reactions to the consultation document had been received by the Ministry of Finance. In a second letter dated 26 October 2009, the State Secretary of Finance indicated that he would soon present legislative proposals regarding the topics of the consultation document.

On 5 December 2009, the State Secretary of Finance sent a third letter to Parliament in which he announced its intention to abandon the plans to introduce the mandatory group interest box and certain measures to restrict the deductibility of interest in the near future. The feasibility of these measures will be taken into account in a broader study of the Dutch tax system, which is currently set up by a specific Study Committee. The government proposes to proceed only with a measure to limit the deductibility of interest incurred by acquisition holdings (we refer to our recent Tax Flash). In addition, the government considers introducing a limitation on the deductibility of losses of foreign permanent establishments. According to an accompanying press release, a legislative proposal is expected in the first half of 2010.

An increase of fines for the failure to file a Tax Return
As from 1 January 2010 the fine for the late filing (or not filing at all) of a corporate income tax return (the “Tax Return”) will be further increased from an amount of € 567 to an amount of € 2,460. The amount of € 2,460 is a fixed amount and does not depend on the number of times the Tax Return has been filed too late in the past, nor the amount of the taxable result. However, in case a taxpayer persists in late filing (or in not filing at all) of Tax Returns, a maximum fine of € 4,920 can be imposed.

The fine of € 2,460 can be imposed for Tax Returns that are filed late (or not at all) on, or after, 1 January 2010. Please note that this new fine does not only apply to Tax Returns for the year 2009 and following years (as the term for filing of these Tax Returns expires after 1 January 2010). It also applies to Tax Returns for years prior to 2009 for which an extension for filing was granted, which extension expires after 1 January 2010.

New social security rules for international labour
Employees who work internationally within the European Union and the European Economic Area (“EEA”) or in Switzerland will be faced with a number of changes when the current Regulation (EEC) No 1408/71 will be replaced by the new Regulation (EC) No 883/2004 on 1 May 2010. The new Regulation provides new rules and conditions to determine which social security system applies to an internationally working employee. In light hereof, existing situations may need to be reassessed. The basic principle of the new Regulation is that an employee is subject to the social security legislation of only one Member State and, as a main rule, this should be the State where the employee pursues his activities (physical presence). The new Regulation contains specific rules for persons who are employed or self-employed in more than one Member State. We note that there will be a transitional period of ten years during which the old regulation will continue to apply for existing situations and the new regulation can be applied upon request.

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Belgium

Administrative Circular on ECJ’s Cobelfret Case
On 12 February 2009, the European Court of Justice (“ECJ”) rendered its decision in the Cobelfret case (C-138/07) on the Belgian dividend participation exemption regime. Belgian legislation provides that dividends received by a parent company from its subsidiary are first included in the taxable basis of the parent company and are subsequently deducted from this taxable basis up to 95% (Dividend Received Deduction or “DRD”). However, this DRD is limited to the positive taxable base of the parent company after deduction of the other exempted profits or deductible costs. Article 4 (1) of the EU Parent-Subsidiary Directive leaves the Member States the choice between the exemption method and the credit method to prevent economic double taxation of dividends. By implementing the dividend participation exemption regime, Belgium opted for the exemption method. However, the Belgian system of the dividend participation exemption regime only allows a parent company to benefit from a full exemption if it has neither realised any losses nor borne deductible costs exceeding 5% of the dividend received during the same tax period. As the Member States cannot unilaterally introduce restrictive measures, the ECJ decided that the Belgian participation exemption regime was not compatible with the terms and objectives of the EU Parent-Subsidiary Directive.

In a response to this ruling, the Belgian tax administration sets out its interpretation of the Cobelfret case in an administrative circular published on 29 June 2009:

The “unused DRD” can now be carried forward to subsequent tax periods. At the moment the taxpayer makes use of it by offsetting taxable profits, it has to demonstrate that, at the time this “unused DRD” was built up, it met all legal requirements to benefit from the participation exemption for dividends received.
The circular also specifies that the “unused DRD” to be carried forward has a specific nature, different from the carry forward tax losses. In other words, this “unused DRD” is not subject to the limitations set forth in the Income Tax Code with respect to carry forward tax losses, e.g. corporate reorganisations and change of control.
The “unused DRD” to be carried forward in principle only concerns the dividends distributed by companies located at the time of the distribution in the EU (including Belgium) or - since 1994 - in the EEA.

Maximum rate of the notional interest deduction
The Notional Interest Deduction regime entitles Belgian companies and establishments to annually calculate a deemed interest expense on their aggregate (adjusted) equity amount, reducing their taxable basis accordingly. The exact amount of the deductible interest expense results from applying an interest rate to the adjusted base amount. This interest rate corresponds to the interest rate for 10-year government bonds. As part of the State Budget for 2010, the Minister of Finance has proposed fixing the maximum rate of the notional interest deduction at 3.8% for the financial years 2010 and 2011 (4.473% for 2009). For small businesses, this rate would be increased by 0.5%. This measure confirms once again that it is not the intention of the Government to fundamentally change the Notional Interest Deduction regime.

Protocol to the UK-Belgian Tax Treaty
On 24 June 2009, the UK and Belgium signed a Protocol to the 1987 UK-Belgian Tax Treaty (the “Protocol”). The Protocol has not yet entered into force. One of the interesting features of this Protocol is that the current Article 11 of the treaty (on interest) is deleted and replaced by a completely new provision. The new Article 11 provides an exemption from withholding tax on interest paid on a loan of any nature granted or a credit extended by an enterprise to another enterprise (compared to the current limit of 15%).

Another interesting feature of this Protocol is certainly to treat the “pension schemes” as resident of the Contracting State where they are established. The Protocol defines a “pension scheme” as any plan, scheme, fund, trust or other arrangement established in a Contracting State, to the extent that it is operated to administer or provide pension or retirement benefits or to earn income for the benefit of one or more such arrangements and provided that this “pension scheme” is:

in the case of Belgium, an entity, including pension funds, or a pension scheme arranged through an insurance company, organised under Belgian law and regulated by the Banking, Finance and Insurance Commission or registered with the Belgian tax administration; or
in the case of the United Kingdom, a pension scheme (other than a social security scheme) registered under Part 4 of the Finance Act, including pension funds or pension schemes arranged through insurance companies and unit trusts where the unit holders are exclusively pension schemes.

In the case of Belgium, the Pension Vehicles (organismes de financement de pensions / organismen voor de financiering van pensioenen) shall therefore qualify as “pension schemes” and thus as Belgian residents for the purposes of the Tax Treaty.

Finally, the Protocol also amends the exchange of information clause in order to bring it in line with the current OECD model.

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Luxembourg

Main changes with effect from 1 January 2009 and 1 January 2010
From 1 January 2009, the following improvements to the Luxembourg tax law took place:

The reduction of the corporate income tax rate from the rate of 29.63% to a general combined rate for Luxembourg City of 28.59%.
The abolishment of Luxembourg capital tax.
A broader domestic exemption from dividend tax. Dividends paid by a Luxembourg company to a shareholder resident in a tax treaty country are exempt from Luxembourg dividend tax if (i) the shareholder is subject to a tax comparable to Luxembourg tax, i.e. statutory tax rate in excess of 10.5% and comparable tax base, and (ii) the shareholder owns at least 10% of the share capital of the Luxembourg company or a participation of which the acquisition price exceeds at least € 1,200,000 for an uninterrupted period of at least 12 months.

On 29 September 2009, the Finance Bill for 2010 was submitted to the Luxembourg Parliament. The Finance Bill extends the exemptions for income tax and net wealth tax, applicable to various organisations (including collective institutions serving the public interest) to similar institutions established in EU Member States. In addition, allowances for business income and agriculture and forestry income received by individuals would be reintroduced. These proposals should enter into force as of 1 January 2010.

Clarifications on Luxembourg IP regime
On 5 March 2009, the Luxembourg tax administration issued Circular LIR no 50bis/1 providing clarifications on the IP regime introduced with effect from 1 January 2008. The IP regime provides for an 80% corporate income tax exemption for income and gains derived from copyrights on software, patents, trademarks, designs, models and domain names. As a result, the effective tax rate on such income is 5.7%.

The Circular provides, inter alia, for the following main clarifications:

IP rights are exempt from net wealth tax as from 1 January 2009.
A common characteristic of IP rights is that the owners have a monopoly with respect to the exploitation or the use of the IP rights in the country for which protection is obtained.
In the case of a split between legal and economic rights, the exemption must be claimed by the economic owner.
Companies and companies of a collective character that have legal personality qualify for the IP regime; transparent entities do not.
If a foreign company migrates to Luxembourg, the original acquisition date of IP held by that company is decisive for the applicability of the regime. The regime only applies to IP acquired or constituted after 31 December 2007. The same rule applies in case of the establishment of a permanent establishment in Luxembourg, or in case a tax-exempt company established in Luxembourg becomes taxable. A step up in basis for the value of the IP is provided for upon migration into Luxembourg.

Exchange of information agreements
In a press release of 13 March 2009, Luxembourg announced that it will comply with the OECD standards on administrative assistance in its tax treaties to combat tax evasion. Luxembourg accordingly dropped its reservations to Article 26 (on exchange of information) of the OECD Model Tax Convention. Since March 2009, Luxembourg has signed new agreements or protocols to existing treaties on exchange of information for tax purposes to implement the internationally agreed tax standard with Austria, Belgium, Denmark, Finland, France, the Netherlands, Norway, Spain, Switzerland, Turkey, the United Kingdom and the United States. In addition, Luxembourg submitted a bill to the parliament on the ratification of recently signed new tax treaties and protocols to existing treaties on 1 October 2009 (after being categorised by the OECD as having substantially met the internationally agreed tax standards). This bill contains the domestic procedural framework necessary for exchanging information upon request. Please note that Luxembourg will not be required to exchange information spontaneously.

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Relevant for all EU countries

Cartesio ruling triggers discussion on tax consequences of corporate emigrations
On 16 December 2008, the ECJ rendered its decision in the Cartesio case. In question was the Hungarian ‘siège réel’ company law system (under which a company is incorporated and exists by virtue of having its corporate seat within Hungarian territory). The ECJ held that a Member State is not required to allow a company incorporated under the company law of that Member State, which subsequently emigrates to another Member State (i.e. transfers its corporate seat to abroad), to continue its corporate existence and legal personality under the company laws of the Member State of incorporation. Nevertheless, that Member State is not allowed to make it impossible or unattractive for that respective emigrating company to convert itself into a company (i.e. continue its corporate life and retain its legal personality) under the company laws of the country of migration (destination country). Hence, the Member State of emigration may not require the emigrating company to be wound up or liquidated upon emigration as far as this company is able to continue its existence and retain its legal personality under the company laws of the destination country.

In its Cartesio ruling, the ECJ paved the way for cross-border transfers of corporate seats in combination with a change of applicable company law. In this respect, Loyens & Loeff is the first firm to have successfully tried and tested this interpretation in practice. Moreover, the ruling triggered discussion on the corporate tax consequences of corporate emigrations as Member States may possibly infringe EU law with respect to:

The exit tax levied upon corporate emigration: It can be argued that the corporate income tax on goodwill, hidden reserves and tax reserves which becomes due upon corporate emigrations (exit tax) is incompatible with EU law. Member States are currently put under some pressure by the European Commission to replace their exit tax systems for lesser restricting alternatives.
The unlimited corporate tax liability for companies incorporated under relevant company law: The Cartesio ruling also lays a foundation for arguing the incompatibility with EU law of the unlimited corporate tax liability for companies incorporated under relevant company law that move abroad. For instance, companies incorporated under Dutch company law are deemed to reside in the Netherlands for corporate income tax purposes irrespective of their actual place of effective management. Such companies are in principle subject to unlimited tax liability. Consequently, upon emigration they may still be confronted with a dual residency for corporate tax purposes.

The Cartesio ruling may encourage companies that have been confronted with an exit tax to challenge their tax liability. In addition, it can be argued that companies should be able to shake off their deemed (e.g. Dutch) tax residency upon emigration, which may encourage emigrating companies to challenge their dual residency for tax purposes.

Glaxo ruling reduced certainty on applicable treaty freedom
On 17 September 2009, the ECJ rendered its decision in the Glaxo case. In question was the German legislation disallowing the deduction of losses from a write-down on the value of participations that were acquired from non-German resident sellers. The court held that the German deduction limitation is compatible with the freedom of capital, subject to the condition that the measure is appropriate and proportional for the purposes of countering tax avoidance.

Interestingly, the Glaxo ruling reduces certainty on the question of which treaty freedom applies with respect to majority shareholdings because the ECJ concludes that the freedom of capital applies. It bases this on the objective and purpose of the respective Member State’s tax legislation at hand (functional approach). This is however different from other rulings (e.g. the Baars and Burda cases) where the ECJ adopts a factual approach by applying the freedom of establishment exclusively in scenarios where the shareholder in fact has a controlling shareholding. Hence, the ECJ seems to inconsistently decide between looking into the objective and purpose of the respective Member State’s tax legislation (functional approach) and looking at the facts and circumstances (factual approach). This leads to uncertainty in scenarios where third countries are involved as the scope of application of the EU treaty freedoms extends to non-EU countries only with respect to capital movements.

The Dutch Supreme Court follows the ECJ’s factual approach. However, it is uncertain whether the Dutch Supreme Court follows the proper lead. As a result of this, the Glaxo ruling encourages taxpayers who find themselves in such scenarios to challenge any obstacles imposed by the Dutch tax legislation.

Deduction of input VAT attributable to the sale of subsidiaries not always limited
On 29 October 2009, the ECJ delivered its judgement in the AB SKF case on the question whether an active holding company can deduct the input VAT on costs incurred in connection with the sale of a subsidiary. AB SKF is the parent company of an international industrial group. Besides holding shares of subsidiaries, AB SKF renders VAT taxed services to its subsidiaries and is considered an active holding company. As part of a group reorganisation, AB SKF intends selling shares of subsidiaries. For these sales, AB SKF received services from third parties.

The ECJ ruled that under circumstances the sale of shares may constitute a transfer of a business going concern. However, if such sale does not qualify as a transfer of a business going concern, the sale of shares by an active holding company is exempt from VAT. On that basis, the input VAT on any expenses directly and immediately attributable to such sale to EU-based purchasers cannot be deducted and, therefore, form a cost for the seller. On the other hand, the input VAT incurred on the sale of shares by an active company to a purchaser residing outside the EU could be deducted. Further, the ECJ ruled that expenses that are not directly and immediately attributable to the sale of shares, but that incurred in light of the general business activities, should be regarded as general expenses. The input VAT on such expenses is generally pro rate deductible calculated on the basis of the overall ratio of VAT-taxed economic activities performed by a VAT-taxable person.

VAT package enters into force
In 2010, the VAT package will enter into force in all EU Member States with a wide range of changes for VAT taxable persons. The main change consists of the introduction of a new general VAT rule for the supply of ‘business to business services’. As of 1 January 2010, services performed to VAT-taxable persons are in principle subject to VAT in the country of residence of the recipient of the services by means of the reverse charge mechanism, i.e. the VAT obligations are shifted from the service provider to the service recipient, including the obligation to report the amount of reverse charge VAT.

Under the revised VAT rules, special place of supply rules will remain in force / be introduced for (among others) services connected to immovable property, restaurant services, passenger transport, the hiring of means of transport, as well as cultural, educational and sporting services. In addition, the Member States have the option to treat services performed outside the EU as being performed within their territory based on the regular rules of supply, provided that the effective use and enjoyment of such services takes place within their territory. Suppliers of services will, further, have to submit a listing of all services that are subject to VAT in other Member States by means of the reverse charge mechanism.

Finally, as of 1 January 2010, EU-based VAT taxable persons will have to file requests for a refund of VAT in other EU Member States electronically with the tax authorities in their country of residence.

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Although this information was composed with the greatest possible diligence, Loyens & Loeff N.V. cannot accept any liability for consequences arising from the use of this information without its cooperation.