The Netherlands Ministry of Finance has issued Notification No. 2024-0000030104 on 5 February 2025, addressing the tax implications of asset transfers during the liquidation of a company within a fiscal unity.

Under the Article 15ai of the Corporate Income Tax Act (CITA), companies are required to recapture gains when transferring assets within a fiscal unity if their fair market value exceeds the book value. After the dissolution of the fiscal unity, the transferring company must revalue these assets at fair market value.

The Notification states that under article 63 of the General Tax Act, the recapture rule for transferred assets does not apply if a fiscal unity dissolves due to the liquidation of a group company under article 15aa (1)(c) of the CITA.