There were multiple programmes of insurance put in place to cover the risk of Dutch withholding tax on various transactions. We did not participate in the first two rounds and liked this particular risk.

The tax risk that was identified was in relation to potential withholding tax due on dividends paid by the Dutch company to its parent company. The company had obtained a tax ruling from the Dutch tax authority that dividends could be paid without Dutch withholding tax on the basis the parent company was tax resident in Singapore. The Singapore tax authority challenged the residency of the parent company in 2021 and determined it was tax resident in the UK, there was a risk that the Dutch tax ruling was invalid.

We issued a primary policy to the company with an initial limit of EUR 62m and an additional limit of EUR 85m on a subsequent policy as shortly after insuring the initial limit of EUR 62m, the Dutch tax authority confirmed they would not pursue this issue.