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.
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 ‘ ...
On April 16, 2024 the Deputy Minister of Finance provided general insights into the upcoming 2025 Tax Plan package in the Tax Policy and Implementation Agenda.
When purely tax-driven and artificial attempts are made to stay (just) outside the formal requirements of Section 10a CITA 1969, the interest deduction can be refused by invoking fraus legis.
Meijburg & Co has updated the overview of the CbCR notification requirements for all countries that have (currently) implemented final CbCR legislation.
Although the method of assessment is less clearly defined than in current qualification policy, the legal forms list may offer more practical certainty.
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2024 have been summarized for your ...
On January 19, 2024 the Dutch Supreme Court clarified the rules applying to the crediting of dividend withholding tax for corporate income tax purposes.