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 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.
The Lower House of the Dutch Parliament has adopted a motion asking the government to propose new legislation with regard to what they call “carried interest”. Specifically, the government was asked t ...
On December 15, 2023 the Ministry of Finance published a new decree on the allocation of taxing rights in respect of severance payments in an international context. The decree took effect on January 1 ...
The vast majority of work-based residence permits issued in the Netherlands every year are for the purpose of employment as a highly skilled migrant or intra-company transferee. To employ these highly ...
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 ...
