The tax structure is not successful, as no Vpb tax unit has been established between the interested party and its subsidiary that participated in the curriculum vitae of the vessel. It was not considered plausible that the interested party held economic ownership of the shares of its subsidiary with regard to the exit option. At the time of the conclusion of the corporate tax unit, it was almost certain that the interested party would sell the shares of his subsidiary for €1, and it did not become plausible that there was a real chance that the shares would have a value of more than €1. For the years 2010 and 2011, the interested party benefited from the temporary regime of arbitrary depreciation provided for in Article 3.34 of the Income Tax Act 2001 (hereinafter referred to as Law Ib 2001) in respect of investment in the vessel in conjunction with Article 13 of the Arbitrary Depreciation Implementing Regulations 2001. On 11 October 2011, the interested party filed his 2010 VPB declaration with a tax base of €2,049,111. In this statement, an amount of € 3,152,502 is included negatively below the results position of the participations. The inspector asked questions. By letter of 26 March 2012, the applicant then sent the inspector the limited partnership contract, the annual figures for the CV tax and a calculation of the depreciation. The inspector discovered that there was a private CV. The inspector also asked his colleagues if there were any issues as a result of the review that might be important for the year 2010. They said there was none. As of October 6, 2012, the inspector made the final vpb 2010 assessment and a loss decision in accordance with the declaration submitted.
Frank Buitenwerf and Roos Jongeneel of Taxand Netherlands examine the main considerations of the tax clauses of a share purchase agreement under Dutch law. At the request of the interested parties and [E BV] of 25 February 2011, the inspector decided, by notification of 21 March 2011, that [E BV] had been added to the tax unit from the date of its establishment ([date] 2010) for the VPB of which the parent company is the interested party. . . .