Corporate Income Tax
Background
We were approached by the broker to insure certain tax risks for a large PE firm who we regularly place policies for. The PE firm was in the process of divesting its shareholding in a trading business which is held through a Dutch and Luxembourg holding structure.
Issue
A tax risk was identified in relation to the amount of Dutch Corporate Income Tax payable as there was some uncertainty around what the base cost of the shares should be.
Solution
We issued a policy to the PE firm with a policy limit of EUR 9 million against the risk that the tax authorities challenged the base cost of the shares to be divested.