25
Oct
By Loyens & Loeff
On 25 October 2017 an Advocate General (AG) of the Court of Justice of the European Union (CJEU) delivered his opinion in two Dutch cases about the consequences of the CJEU judgment in the French Groupe Steria case for the Dutch tax consolidation regime (fiscal unity) in situations concerning (i) the Dutch interest deduction limitation rule to prevent base erosion and (ii) the non-deductibility of currency losses on a participation in a non-Dutch/EU subsidiary. Loyens & Loeff...