deelnemingsverrekening

13:39 Aug 23, 2014 

Good try. But it's still called double taxation relief (cf. Phil G's last two suggestions) and is bog-standard double taxation terminology.

13:23 Aug 23, 2014 

No idea whether this is the actual term used but it does work in both instances in context. The terms 'offset', 'rebate' and 'double taxation' come up a lot in this context. (As I understand it it is double taxation on dividends or other profit on equity in two related companies that the offset or 'verrekening' would relieve.)

15:02 Aug 22, 2014 

"Participation credit" or "participation relief" or "subsidiary relief" would get my vote.

13:10 Aug 22, 2014 

True. However, JurLex is more often right than wrong, so that is a risk I am willing to take.

12:59 Aug 22, 2014 

The trouble with posting Jurlex without actually knowing oneself is that it could be one of those times Jurlex is wrong.

12:59 Aug 22, 2014 

That looks more like the business.

12:51 Aug 22, 2014 

I posted the JurLex Reference comment in case he doesn't own JurLex. Just trying to help.

I have no idea what this means myself.

12:47 Aug 22, 2014 

and easily found but it's not supposed to be a 'fishing expedition'. André is looking for someone who actually knows what the right term is and is able to provide an explanation. Fwiw, I don't know either.........

12:27 Aug 22, 2014 

‘Amendment to the participation exemption
Currently, the participation exemption does not apply to ‘low-taxed portfolio investments’. Instead of the participation exemption (deelnemingsvrijstelling), the participation loss relief facilities (deelnemingsverrekening) will be applicable to such participations. A participation is considered a low-taxed portfolio investment if more than 50% of the assets held directly or indirectly by the participation consists of free portfolio investments (‘asset test’) and the participation is not liable to a tax according to the profit which, in accordance with Dutch standards, results in a tax liability of 10% or more (‘rate test’). An exception exists for the ‘real estate subsidiary’ (vastgoeddeelneming).’

(http://www.loyensloeff.com/en-US/News/Publications/Newslette... )

12:24 Aug 22, 2014 

See e.g.:

‘(iii) is an entity that has an interest in us to which the participation exemption (deelnemingsvrijstelling) or the participation credit (deelnemingsverrekening) is applicable as set out in the Dutch Corporate Income Tax Act 1969;

[…]

(ii) the entity at the time of the distribution has an interest in us to which the participation exemption as meant in article 13 of the Dutch Corporate Income Tax Act 1969 or to which the participation credit as meant in article 13aa of the Dutch Corporate Income Tax Act 1969 (Wet op de vennootschapsbelasting 1969) would have been applicable, had such entity been a tax resident of the Netherlands;’

(http://www.sec.gov/Archives/edgar/data/1563411/0001193125132... )