According to Gazprom (as quoted by RFERL) the Dutch government has suspended the license of South Stream Transport B.V., which apparently is a Gazprom subsidiary registered in the Netherlands. South Stream Transport B.V. operates at least the maintenance of TurkStream, which they now say they can't do anymore due lack of a Dutch license.

But TurkStream runs between Russia and Turkey, albeit to the European side of Turkey, so from there gas goes to Serbia, Hungary etc. (according to RFERL). So why would Gazprom hand over a degree of control over this Russia-Turkey pipeline to the Dutch, by registering their subsidiary in the Netherlands? Is this related in some way to some EU regulations or requirements, since some gas customers of the pipe are in the EU, or was it purely Gazprom's decision for other reasons?

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    If i should guess, i would say tax reasons.
    – Sascha
    Sep 30, 2022 at 9:15
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    @Fizz: Still, Gazprom would not want to pay more taxes in the EU than needed. It's not an accident than many holdings and european companies operate from the Netherlands.
    – Sascha
    Sep 30, 2022 at 10:43
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    @Sascha: yeah, if they were forced to use a EU company/subsidiary, then Netherlands would probably have been a good choice. The questions is whether they were forced by some law/regs (or even political pressure of some knid) or not. Sep 30, 2022 at 10:45
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    @user253751: Turkey is not in the EU. Oct 2, 2022 at 4:33
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    @Fizz: No, but Turkey is an EU candidate, and there are a number of treaties which allow Turkish companies into the EU and vice versa. Economic integration has always been easier. And then the Russians have the advantage that a Russian-Turkish dispute can be fought in a neutral court in the Netherlands. Dutch courts have experience with such international lawsuits. The alternative would have been London.
    – MSalters
    Oct 3, 2022 at 13:21

1 Answer 1


Russian jurisdiction is not considered to be reliable enough (by Turkey and maybe even by Russian parties) to operate such a large joint project. Neither is Turkish jurisdiction. If there is a disagreement and it is registered in one of these countries, naturally you go to this country's court where one side has a huge advantage.

Yandex had (maybe is still having?) its main company registered in the Netherlands as well, and their Russian ООО Яндекс is a wholly-owned subsidiary of Yandex N.V. So it's not an unique situation where a Russian company having virtually no capital in Netherlands is registered there.

Choosing a neutral jurisdiction with reliable rule of law that is staked in any court case - not only the Dutch are judging the Turkey vs. Russia case, but the whole world also judges the results of the Dutch court to validate if it still can be trusted.

This situation may be backfiring now when EU may be having a conflict of interests (wrt Russia) larger than the losses from long-term reputational damages arising if they choose to weaponize their jurisdiction.

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    "choose to weaponize their jurisdiction" - that implies there is a possibility. This is likely not the case. The Dutch bar forces lawyers to represent Russian companies, despite the sanctions, since the bar considers the right to a fair trial more important. Dutch judges similarly would be not very impressed by a government desire to "weaponize" the courts.
    – MSalters
    Oct 6, 2022 at 7:29
  • I think you know the Chekhov's saying about guns and last acts.
    – alamar
    Oct 6, 2022 at 9:43

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