The amount to be paid agreed in 2019 pertains to the transfer of the company in 2014

In 2014, agreements were made between VOF X and Stichting X for the transfer of assets, right of use, takeover of care activities, and rental of office space.
In 2019, a settlement agreement was reached between the partners of VOF X (now VOF A) and Stichting X for compensation.
The dispute is whether the amount agreed upon in 2019 is related to the 2014 transfer.
The court believes that the company was transferred in its entirety to Stichting X in 2014, despite the unfortunate way in which the agreements were recorded.
The payment in 2019 is part of the transaction and falls under Section 37d of the OB Act. The details of the transfer are not relevant for the application of this section.

Taxable transaction