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 11 March 2021, a legislative proposal for an Act on responsible and sustainable international business been submitted to the Dutch Parliament Wetsvoorstel verantwoord en duurzaam internationaal ond ...
The Dutch tax authorities recently published its Foreign workers and payroll taxes report. The report offers practical guidelines for payroll tax matters in international situations.
As of 2024, the Pillar 2 rules will become a reality within the EU and other jurisdictions worldwide. Under Pillar 2, the Global Anti-Base Erosion (GloBE) rules ensure that large multinational enterpr ...
Have you completed your accounts for the work-related costs rules (WCR)?The deadline for 2022 is fast approaching. If your WCR accounts show that you exceeded the discretionary margin in 2022, then th ...
On Friday, January 27, 2023 a draft bill was published that must introduce a temporary levy on the market revenues from inframarginal electricity production.
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2023 have been summarized for your ...
On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.
In this memorandum, we highlight the main (IFRS) tax accounting consequences of the 2023 Tax Plan and some other tax developments relevant to the 2022 financial statements.