The transfer of production, research, development and service activities out of the Netherlands

The Dutch tax authorities take in practice a critical look at the costs made by Netherlands resident subsidiaries of foreign multinational enterprises regarding the reorganization or closing of business operations in the Netherlands. These operations are often combined with a continuation of e.g. production or service operatins in e.g. China or India. The authors present the lines along which in their view the issue of the deductibility of the reorganization costs has to be dealt with.