Court dismisses appeal against capital gains tax on silent share transfer due to failure to meet statutory balance conditions.

The Court of Appeal of Arnhem upheld the tax authority's decision to impose a capital gains tax of 7,330 guilders on a silent share transfer. The taxpayer argued for a tax exemption based on a specific balance sheet date, but the court found the statutory conditions for such an exemption were not met. Consequently, the court rejected the taxpayer's appeal and confirmed the tax liability.