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A taxpayer inquired whether the 10% capitalisation reserve reduction could be applied to only a portion of their increase in equity, with the remainder distributed as dividends. The Directorate-General for Taxes (DGT) ruled that the regulations do not prevent applying the reduction to an amount lower than the total calculated increase.
This ruling provides flexibility for companies to optimise their tax position by selectively applying the capitalisation reserve reduction while still allowing for dividend distributions from the remaining equity increase.
The tax team reviews your specific situation.
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