Bosal Holding and the confusion surrounding the territoriality principle

Journal
International Transfer Pricing Journal 2003 (Volume 10), No. 3
Discusses the factural constellation in the Bosal Holding B.V case as well as the Netherlands participation exemption and examines the Netherlands participation exemption in light of the Parent-Subsidiary Directive and in light of the right of establishment. The possible consequences of an ECJ ruling are also discussed and, in particular, the consequences for participation exemptions outside the European Union.