Important judgment on tax classification of financial instrument
On May 17, 2024 the Dutch Supreme Court rendered an important judgment on the tax qualification of a financial instrument that was issued by a company established in France in 2007. It concerned the ‘obligation remboursable en actions’ (hereinafter: ORA). The question was whether the instrument had to be regarded as equity (capital) or debt capital (loan) for the purposes of the Corporate Income Tax Act 1969. Although the dispute focused on the question whether the costs related to the issue of the instrument were allocable to a Dutch permanent establishment of the French company, the Supreme Court judgment potentially has a much broader scope.
Money worries can seriously impact the (mental) health of employees. This ultimately increases the risk of absenteeism due to sickness and employees who are off work for extended periods of time. A se ...
The new Dutch Transfer Pricing Decree was published on July 1, 2022. The new decree focuses on recent developments that have resulted in changes to the OECD Transfer Pricing Guidelines but also ...
