This edition of Quoted discusses the application of the new loss compensation rule and topics of practical interest.
The contribution is structured as follows:
- first, we describe the new loss compensation rule in corporation tax and illustrate its effect with two examples (section 2);
- second, we discuss the concurrence with the debt waiver income exemption, as well as the concurrence with the revaluation option provided by article 20a, paragraph 12 CIT Act (sections 3 and 4);
- third, we discuss the concurrence of the new loss compensation rule with the fiscal unity in the context of offsetting pre-fiscal unity losses (section 5);
- fourth, we examine the meaning of the Dutch sound business principles and the timing of income and expenses under the new loss compensation rule (section 6);
- last, we address offsetting holding company and financing losses (section 7).
Where necessary, the different sections end with some practical conclusions and points to consider.