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Netherlands: Interest deductions may be denied under interest deduction limitation rules even if taxable to recipient (Supreme Court decision)

Decision of Dutch Supreme Court issued May 1, 2026

June 15, 2026

In addition, the Dutch Supreme Court on May 1, 2026, held that interest deductions may be denied under section 10a and fraus legis when financing structures lack sufficient commercial substance, even if the corresponding income is taxed at the recipient level.


For more information, contact a KPMG tax professional in the Netherlands:

Paul Te Boekhorst | teboekhorst.paul@kpmg.com

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