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.

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Tax Update Shipping & Offshore - July 2023

March 4, 2024
This is the third Tax Update for the Shipping & Offshore sector for 2023.
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Tax Update Shipping & Offshore - July 2023

February 2, 2024
This is the third Tax Update for the Shipping & Offshore sector for 2023.
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Tax Update Shipping & Offshore - July 2023

October 25, 2023
This is the third Tax Update for the Shipping & Offshore sector for 2023.
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Tax Update Shipping & Offshore - July 2023

July 7, 2023
This is the third Tax Update for the Shipping & Offshore sector for 2023.
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Tax Update Shipping & Offshore - May 2023

May 23, 2023
This is the third  Tax Update for the Shipping & Offshore sector for 2023.
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Tax Update Shipping & Offshore - April 2023

April 5, 2023
This is the second Tax Update for the Shipping & Offshore sector for 2023.
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Tax Update Shipping & Offshore - January 2023

January 25, 2023
This is the first Tax Update for the Shipping & Offshore sector for 2023.
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VAT in the Digital Age proposal issued to modernize the EU VAT system

December 9, 2022
The proposal from the European Commission covers three issues: (1) Digital Reporting Requirements (2) the VAT treatment of the platform economy and (3) changes to e-commerce rules and a ‘single VAT re ...
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Taking stock: BEPS Action Plan as it relates to the ‘control over risk’ concept

March 18, 2021
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Factsheet: Dutch tonnage tax regime

October 4, 2020
The tonnage regime is a favorable tax regime that was introduced in the Netherlands in 1996 and which can help parties in the maritime / offshore sector to successfully operate in an internationa ...
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Tax measures for 2021

September 16, 2020
The main features of the 2021 Tax Plan package are addressed in our memorandum
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The 2021 Tax Plan on two pages

September 16, 2020
We have prepared a two-page overview of the measures contained in the 2021 Tax Plan package.
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