Existence of a Partnership Between Interested Party, [Y], and [Z] for Sint Maarten BBO Tax Purposes

• The taxpayer claims there is a partnership between themselves, [Y], and [Z], so transactions between them should not be subject to BBO tax.
• The Inspector disagrees, stating there is no partnership.
• The court finds that the three entities are each independent entrepreneurs: the taxpayer rents out real estate, [Y] operates a hotel/restaurant, and [Z] operates a casino.
• The court rules there is no contractual partnership or joint venture; each entity is taxed separately, even if there are financial or organizational links.
• Therefore, the answer to Question I is negative: there is no partnership for tax purposes.

Source: uitspraken.rechtspraak.nl

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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