According to the court, there is no abuse of law. This is not a combination of transactions of an artificial nature, but a purchase and sale agreement between a BV and its DGA. The BV thereby transfers the Volvo directly against the pre-agreed fee. The saving of VAT due to the low compensation is insufficient to conclude that there has been an abuse of law. There is no provision in Dutch law that corrects the compensation in affiliated relationships to the normal value.
Source: taxence.nl
