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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LIBOR transition - Transfer Pricing considerations (updated April 2022)

April 19, 2022
Throughout the world, a transition is currently taking place from interbank offered rates (IBORs) to alternative benchmarks. Per January 1, 2022, LIBOR (London Interbank Offered Rate) - a referen ...

Pro Memoria 2022

January 25, 2022
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2022 have been summarized for your ...

Tax aspects of 2021 coalition agreement

December 16, 2021
We briefly address what is currently known about the intended tax measures.

The 2022 Tax Plan on two pages

September 21, 2021
We have prepared a two-page overview of the measures contained in the 2022 Tax Plan package.

Relief and recovery package fourth quarter 2021

August 31, 2021
By letter to the Lower House of Parliament dated August 30, 2021 the caretaker government announced that as of October 1, 2021 the generic relief and recovery package would largely end.

Relief and recovery package for the economy and labor market also available in the third quarter 2021

May 28, 2021
The extension of the relief package means, among other things, that the NOW and the TVL will also be available to businesses in the third quarter of 2021.

Expansion of corona support in connection with extension of lockdown (January 2021)

January 22, 2021
On January 21, 2021 in a letter sent to the Lower House of Parliament the government announced that the current relief and recovery package for the economy and labor market would again be expanded.

Relief and recovery package for the economy and labor market reappraised

December 14, 2020
In a letter sent to the Lower House of Parliament on December 9, 2020 the government announced that the existing relief and recovery package for the economy and labor market  – which was announce ...

Lower House of Parliament adopts 2021 Tax Plan package and bill on the Liquidation and Cessation Loss Schemes Limitation Act

November 13, 2020
We have briefly outlined the adopted tax amendments and a selection of the adopted motions.

Relief and recovery package for the economy and labor market (Emergency package 3.0)

September 2, 2020
On August 28, 2020 by letter to the Lower House of Parliament, the government presented a relief and recovery package for businesses and workers, which follows on from the two previous emergency packa ...

Q&A: Tax policy developments for governments and multinationals

July 17, 2020
The European Green Deal suggests that well-designed tax reforms can boost economic growth and help reduce greenhouse gas emissions by ensuring an effective carbon pricing.

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