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How to have a tax efficient structure in Netherlands?

Im investing in Eastern Europe properties through a Netherlands structure. However due to most properties incurring huge losses, I still pay a huge bill in Netherlands as some of the Netherland entities loan interest is not deductible creating a inefficient tax structure. How can I restructure this and ensure that tax I pay reflects the performance of the underlying structures.

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    Virtually all corporate entities established and residing in the Netherlands are subject to Dutch corporate income tax for their worldwide profits. If you have a number of Dutch entities, the good news is that the Dutch corporate income tax act provides for the possibility of a consolidate tax regime, referred as “fiscal unity”.
    A fiscal unity, which is optional, is a combination of parent and subsidiary companies, whereby formally the parent (owning at least 95% of all of the issued share capital of the other company) is the entity that is taxed for the consolidated profits of the fiscal unity. The advantages of a fiscal unity are that profits and losses of group companies can be offset against each other. This means that transactions between group companies can be eliminated for tax purposes and hence assets can under certain conditions be transferred within the group without triggering taxable capital gains.

    Hope this helps.


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