ACHMEA increases provision for PZU tax case after Dutch court ruling
The increase follows a ruling by the Dutch court Arnhem-Leeuwarden, whereby ACHMEA's views have been partially taken into account. On the basis of the ruling, a larger amount of the PZU settlement is subject to Dutch corporate tax than cautiously anticipated in building up the provision in previous years.
ACHMEA disagrees with the Dutch tax authority on the fiscal treatment in The Netherlands of the compensation received for the divestment of its shareholding in PZU, in the years 2009 en 2010. The agreement with the Polish government at the time resulted in total proceeds for ACHMEA of EUR 4.2 billion. The disagreement with the Dutch tax authority is regarding the tax treatment on the amount received of 1.2 billion euros. ACHMEA is of the opinion that this amount should be exempted from Dutch corporate tax. The court has ruled that of the amount received of approximately EUR 1.2 billion, an amount of EUR 248 million is exempted from corporate tax.
ACHMEA is in the process of analysing the ruling by the Court en will decide at a later moment whether it will file an appeal with the Dutch Supreme Court. The impact of the increase of the provision will be accounted for in the results over the first half of this year.